Privacy Notice
Effective Date: August 22, 2025
This Privacy Notice (“Privacy Notice”) explains how ZO Skin Health, Inc. (“ZO”, “us”, “our”, or “we”) collects, uses, and discloses personal information. It applies to individuals (“users”, “you”, or “your”) who visit www.zoskinhealth.com, www.zoskinhealth.ca, and other websites controlled by ZO (collectively, the “Site”), create an account, interact with us offline, and/or make purchases through the Site or other sites or services that link to this Privacy Notice (collectively, the “Services”). This Privacy Notice also covers the personal information we collect in a business-to-business context. Please note that the personal information we collect about you may vary depending on whether you are a ZO customer or business contact.
We encourage you to read this Privacy Notice carefully to understand how we handle your personal information. By using the Services, you acknowledge that you have read and understand this Privacy Notice and that we collect, use, and disclose your information as set forth below. If you have any questions regarding this Privacy Notice or our privacy practices, please email us at privacy@zoskinhealth.com.
We will occasionally update this Privacy Notice. When we post changes to this Privacy Notice, we will revise the “Effective Date” at the top of the Privacy Notice. Please note that any changes to this Privacy Notice are effective immediately upon publication, and your continued use of the Services indicates your acknowledgement of these changes. We recommend that you check our Site from time to time to inform yourself of any changes to this Privacy Notice.
As used in this Privacy Notice, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal information does not include information that is publicly available, de-identified, or aggregated.
If you are a California resident, click here to view additional disclosures pursuant to the California Consumer Privacy Act.
TABLE OF CONTENTS
- PERSONAL INFORMATION WE COLLECT
- TO WHOM WE DISCLOSE YOUR PERSONAL INFORMATION
- COOKIES AND OTHER TRACKING TECHNOLOGIES
- YOUR CHOICES
- CONTACT US
PERSONAL INFORMATION WE COLLECT
ZO may collect personal information from the following sources:
Directly from you. For example, when you create an account, make a purchase, input information into a form on our Site, email us, or engage with us on social media.
Automatically through cookies and other tracking technologies. For example, via cookies and tracking technologies on our Site or in our email communications (see “Cookies and Other Tracking Technologies” below for more information).
From other sources. For example, or vendors, partners, and social media platforms.
We may collect the following categories of personal information. These examples may vary depending on the nature of your interactions with us, including if you interact with us in a business context.
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Category of Personal Information |
Purpose for Collection, Use, or Disclosure |
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Identifiers and Personal Records, such as name, email address, telephone number, mailing address, IP address, financial information, physical characteristics or description, account name and password, and profile pictures when you choose to interact with us on social media.
This category includes information described in Cal. Civ. Code § 1798.80(e). |
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Characteristics of Protected Classifications, such as gender. |
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Commercial Information, such as products purchased, obtained, or considered, subscription information, or other purchasing tendencies. |
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Internet or Other Electronic Network Activity Information, such as browsing history, search history, IP address, keystrokes and scrolls, device identifiers, and information regarding online interactions, including interactions over time across the internet, the Site, and advertisements. |
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Geolocation Data, including approximate location based on your device IP address or interaction with the Authorized Partner tool. |
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Sensory Data, including audio recordings of customer care calls. |
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Professional or Employment-Related Information, such as employer, job title, and similar information. |
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Inferences about your preferences and interactions with our Services. |
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Profile Information, such as information about your skincare needs. |
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Contents of Communications, including any information you choose to share with us when you communicate with us via email, webform, chat, telephone, or otherwise. |
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We may combine the personal information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Notice. We may also collect, use, and disclose the categories of personal information identified above to comply with legal requirements and enforce our policies, and to protect the safety, rights, property, or security of ZO, our users, employees, members of the public, and/or our Services.
TO WHOM WE DISCLOSE YOUR PERSONAL INFORMATION
We may disclose your personal information to:
Subsidiaries and Affiliates. We may disclose your personal information to our subsidiaries and affiliates.
Service Providers. We may disclose your personal information to vendors that perform certain services on our behalf, such as processing orders, processing credit card payments, delivering products and services, providing customer service and marketing assistance, performing business and sales analysis, supporting our website functionality, and supporting other features and promotions offered through our Site. We will only provide these service providers with the personal information that they need to provide such services, and service providers are not permitted to share or use such information for other purposes.
ZO Authorized Partners. When purchasing products on our Site, you may choose one of the many ZO Authorized Partners across the country before completing your purchase. When selecting a ZO Authorized Partner in checkout, you can choose to allow us to disclose personal information to your selected ZO Authorized Partner. If you choose for us to disclose your information in this way, we will disclose certain personal information to the ZO Authorized Partner who you selected.
Business Partners. From time to time, we may offer promotions, sweepstakes, or third-party offerings on our Site. If you make purchases or engage in these services and/or products offered through our Site or our Services, we may disclose personal information to the businesses with which we partner to offer you those products, services, promotions, contests and/or sweepstakes. When you elect to engage in a particular merchant’s offer or program, you authorize us to provide your email address and other personal information to that merchant.
Other Users of the Services. We may provide areas on the Services where you can communicate with others, upload content, and post comments or reviews. If you choose to share information in this way, you share such information with all individuals capable of viewing it. For example, if you post a comment on a publicly viewable area of the Services, you choose to share the information you post with the public. We encourage you to exercise discretion and caution with respect to sharing your information.
Business Transfers. We may disclose your personal information in connection with a merger, acquisition, reorganization, assignment, sale of assets, or other corporate transactions, or in the event of bankruptcy.
Legal Obligations, ZO may disclose your personal information in good faith in response to a subpoena, court order, or other legal process from law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.
COOKIES AND OTHER TRACKING TECHNOLOGIES
A cookie is a small data file that is stored by your browser on your device. We use cookies to deliver a better experience, for example, remembering your preferences.
Other examples of why we use cookies include:
- To learn about how you interact with our Site
- To detect and prevent fraud
- To conduct analytics activities
- To improve our Services
- To facilitate interest-based advertising
If you use your browser’s method of blocking or removing cookies, some, but not all, types of cookies may be deleted and/or blocked. If you delete or block cookies, some functionality on our Site may not work properly.
In addition to cookies, we may use other types of tracking technologies in connection with our Services.
Analytics. We may use third-party web analytics services (such as Google Analytics) on our Site to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. Information about Google Analytics’ current opt-outs for web is available here.
We may integrate the analytics services we use with advertising services that are made available by our analytics providers. For example, we integrate Google Analytics with the following Google advertising features:
- Remarketing with Google Analytics
- Cross Device Remarketing & Reporting
- Google Analytics Demographics and Interest Reporting
- Google Display Network Impression Reporting
If you receive email from us, we may use certain analytics tools, such as tracking pixels, to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
Session Replay Technology. We may use session recording and replay technology to observe your mouse movements, scrolling, and clicks on our Site. We use these tracking tools for support and analytics purposes, and to better understand how people engage with our Site. This information is often collected and processed by our service providers who we have engaged to analyze this information on our behalf.
Online Advertising. For more information about tailored advertising and how you can generally control the cookies being placed on your device to deliver tailored advertising, please visit the Network Advertising Initiative’s Consumer Opt-Out link, or the Digital Advertising Alliance’s Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in those programs.
Modifying your mobile device or browser settings may have different results depending on the type of device or browser you are using and the version of the device operating system you are running. Opting out of tailored advertising does not prevent you from seeing advertising online; instead, the ads you see are less likely to be customized to your interests.
Any third-party practices are not governed by this Privacy Notice.
YOUR CHOICES
We provide several ways for you to exercise control over how we use information about you and how we communicate with you, described below.
Marketing Emails. Consistent with your choices and in compliance with applicable law, we may send you marketing and promotional emails. You may opt out of these emails by clicking unsubscribe at the bottom of our marketing emails. It may take up to 10 days for us to process an opt-out request. You will still receive transactional communications from us, such as confirmation of your purchase with us.
Marketing Text Messages. You may elect to receive marketing text messages from us. You can opt out of marketing text messages at any time by replying “STOP” to any of our messages. For more information on our marketing text messages, please see our SMS terms.
“Do Not Track” Signals. The Site does not respond to “Do Not Track” signals sent by browsers, mobile devices, or other mechanisms.
Social Media. To control the personal information you share with us when you follow us, like our posts, or otherwise interact with us on social media, you can adjust your social media account settings related to how your information is shared.
We may retain your personal information for as long as is necessary for the purposes described in this Privacy Notice, which generally means holding the personal information for as long as one of the following applies:
- Your personal information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the personal information;
- Your personal information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was collected; or
- We are otherwise required or permitted to keep your personal information by applicable laws or regulations.
Where personal information is used for more than one purpose, we will retain it until the purpose with the latest period expires.
ZO maintains appropriate security measures (including physical, electronic, and procedural measures) to help safeguard your personal information. However, we cannot guarantee the security of such information because no security measures are perfect. We are not responsible for third-party circumvention of any of our privacy settings or security measures.
You can also take steps to safeguard your personal information. If you create an account on our Site, you will be required to select a password which should be kept confidential and be of appropriate complexity. You should also limit access to your devices and account to avoid unwanted access to your personal information. For example, you should always log out of your account after using it on a shared device.
The Services may link to third-party websites. We do not control, recommend, or endorse such websites. We are not responsible for and make no representations about such websites or their content, services, or practices. This Privacy Notice does not govern any third-party websites. Thus, we encourage you to review the privacy policies of any third-party websites you choose to visit to understand how those websites collect, use and share your information.
Our Services are not directed to or intended for children under the age of 13, and we do not knowingly collect “personal information” (as defined in the U.S. Children’s Online Privacy Protection Act, or “COPPA”) from children under the age of 13.
The Services are operated in the United States and are subject to United States law. We may store and process personal information in the United States. If you are accessing the Services from outside the United States, please be advised that United States law may not offer the same privacy protections as the law of your country. By using the Services, you acknowledge the transfer, processing, and/or storage of your personal information in the United States. If you are a user located in the United Kingdom, the European Economic Area, or Switzerland, click here to view our international Privacy Notice. If you are a user located in Canada, please refer to the “Additional Disclosures for Residents of Canada” section below.
The disclosures in this section supplement our general Privacy Notice and apply to residents of California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Nevada, Oregon, Tennessee, Texas, Utah, and Virginia (each a “Covered State” and collectively, “Covered States”).
Sales, Sharing, and Targeted Advertising
From time to time, we may use or disclose your personal information in a manner that is considered a “sale” or “share” for cross-context behavioral advertising or targeted advertising purposes. We do this in order to provide the most relevant advertising and personalized offers. The categories of third parties to which we share your personal information include analytics, advertising, and technology companies.
The categories of personal information that we may sell or share for targeted advertising include identifiers, commercial information, internet or other electronic network activity information, geolocation data, and inferences. We do not knowingly sell or share the personal information of consumers under the age of 16.
Your Rights Under Covered State Privacy Laws
If you are a resident of a Covered State, subject to certain exceptions, you have the following rights regarding your personal information:
- Right to know/access. You have the right to request access to and obtain a copy of your personal information that we process.
- Right to correct. You have the right to request that we correct inaccuracies in your personal information.
- Right to delete. You have the right to request that we delete your personal information.
- Right to opt out of the sale of personal information. You have the right to request that we stop disclosing or making available your personal information in a way that is considered a “sale.”
- Right to opt out of sharing and targeted advertising. You have the right to request that we stop sharing your personal information for cross-context behavioral advertising and/or targeted advertising.
- Right to appeal. If you are unsatisfied with our resolution of your request, you may appeal our decision.
- Delaware and Maryland. If you are a resident of Delaware or Maryland, you have the right to request a list of the categories of third parties to which we disclose your personal data.
- Minnesota and Oregon. If you are a resident of Minnesota or Oregon, you have the right to request a list of third parties to which we disclosed personal data.
We do not profile in a manner that would result in legal or similarly significant effects, and as such do not offer a right to opt out of profiling. Likewise, we do not process sensitive data as defined by Covered State privacy laws.
You will not be discriminated against for exercising these rights. We will not deny you any services, nor charge you different prices, in retaliation for exercising your privacy rights.
How to Exercise Your Rights Under Covered State Privacy Laws
To exercise any of these rights, please submit a request by email to privacy@zoskinhealth.com or call us at (888) 893-1375. We will only use the personal information that you provide in a request to authenticate the request. We will not further disclose the personal information and will retain it only as necessary for the purpose of authentication and to meet our legal obligations. We cannot fulfill your request if we cannot authenticate it and confirm that the personal information relates to you.
To opt out of sales, sharing, and targeted advertising via cookies, click on the “Your Privacy Choices” link in the footer of the Site and manage your preferences. You may also opt out of cookie-based sales, sharing and targeted advertising by using the Global Privacy Control preference signal. Your opt-out request will be applied on a browser and device basis, and you will need to set your preferences for each browser and device you use. Your selections will be lost if you clear your cache and cookies.
Authorized Agents
In certain states, you may designate an authorized agent (a person or entity acting on your behalf) to submit a request on your behalf. Unless otherwise allowed by law, we will not act on a request from an authorized agent unless we are able to authenticate, with commercially reasonable effort, both your identity and the authorized agent’s authority to act on your behalf.
Oregon
Oregon residents, please note that the controller of your personal information is ZO Skin Health, Inc.
Nevada
If you are a Nevada resident you may have additional rights which you can exercise by sending an email to privacy@zoskinhealth.com.
Consent
By providing (or authorizing another person or organization to provide) your personal information to us, you consent to our collection, use, disclosure, and retention of your personal information as described in this Privacy Notice and as otherwise permitted by applicable law. We might also obtain your additional consent in certain circumstances, including when required by law, to collect, use, disclose, or retain your personal information for other specific purposes. You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to us, but then you might not be able to proceed with your intended interactions or transactions with us or otherwise receive the full benefit of our products and services. Please refer to section titled “Your Choices” above to learn about withdrawing your consent. In addition, where permitted by applicable law, we may collect, use, disclose, and retain your personal information without your consent.
Withdrawing Consent
In addition to the choices you have about the way we handle your personal information described elsewhere in this Privacy Notice (including the section titled “Your Choices”), you may withdraw your consent to our collection, use, and disclosure of your personal information as explained in this Privacy Notice at any time on reasonable written notice to us, subject to legal or contractual restrictions. To withdraw your consent, you may contact us at privacy@zoskinhealth.com.
If you withdraw your consent to our collection, use, and disclosure of your personal information for purposes that are integral to our relationship and dealings with you or your access to or use of the Services, then you might not be able to proceed with your intended dealings with us or otherwise access, use, or receive the full benefit of the Services. If you currently use the Services, then your withdrawal of consent will require you to terminate the Services that you currently use.
If you withdraw your consent to our collection, use, and disclosure of your personal information for purposes that are not integral to our relationship and dealings with you or your access to or use of our products and services, then withdrawing your consent for those purposes will not affect your access to or use of the Services.
If you withdraw your consent to our collection, use, and disclosure of your personal information, we may retain and use your personal information to comply with applicable law, to establish, enforce and exercise our rights and remedies, and for other purposes permitted by applicable law.
Your Rights
You may reasonably request access to your personal information under our legal control and information about our use, disclosure, and retention of your personal information by contacting us using the contact information set out below. Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your personal information and you will be entitled to verify the accuracy and completeness of your personal information and have the information corrected as appropriate. You might be required to pay a reasonable fee for access to your personal information. We may decline to process an access request that is unreasonably repetitive, frivolous, vexatious, or impracticable, or if we reasonably believe the requested access would infringe or jeopardize the privacy of other persons, violate any applicable law or legal requirement, or for other reasons permitted by applicable law.
Depending on the jurisdiction where you reside, you may also be entitled to request the rectification, deletion or data portability of your personal information under our legal control or information about our use of automated decision-making with respect to your personal information under our legal control.
If you reside in the Province of Québec, you may also be entitled to make a request to obtain certain other information related to your personal information, including the information that was provided to you at the time of collection of your personal information, categories of persons who have access to your personal information within ZO, the length of the period for which ZO will retain your personal information and, if the personal information was not collected directly from you, the source from which ZO collected the personal information.
CONTACT US
If you have any further questions regarding the personal information we collect, or how we use it, please feel free to contact us by email at: privacy@zoskinhealth.com, via phone at (888) 893-1375, or in writing at:
ZO Skin Health, Inc.
9685 Research Drive
Irvine, CA 92618
USA