Privacy Policy

EFFECTIVE DATE: DECEMBER 1, 2019

General Purpose

Imalac has developed this Imalac, Inc. Privacy Policy and Cookie Policy (the “Privacy Policy”) to demonstrate its commitment to protecting the personal and private information of those using the ​Imalac.com Website (the “Website”). Imalac, including its affiliates, is committed to protecting the privacy of users of our Website.

This Privacy Policy sets forth how we collect information from users of our Website and how we use that information (e.g., your name, age, address, telephone and cell number and email address). When you provide information through our Website, the information may be sent to secure network servers located in the United States and/or other countries.This Privacy Policy is based on privacy and data protection principles common to the countries in which we operate. This Privacy Policy is intended to summarize and inform you of our general online privacy and data protection practices regarding the collection, use, and disclosure of information when you use our Website, and the choices you have with respect to that information. Please read this Privacy Policy carefully.

This Privacy Policy forms part of our Terms and Conditions. To read our Terms and Conditions, click here.

Acceptance of Privacy Policy
By accessing the Website, you acknowledge the terms of this Privacy Policy. If you do not acknowledge the terms of this Privacy Policy, please do not use this Website. This Privacy Policy may change from time to time. Each time you use the Website, the current version of the Privacy Policy will apply. Accordingly, when you use the Website, you should check the last modified date of this Privacy Policy (which appears below) and review any changes since the last version.

Communications, Disclosure and Use of Your Communications
We may collect information when actively submitted by users and based on users’ visits to, interactions with, and activity on our Website. We may use various technologies as well (e.g., cookies) to collect information from your device and about your activities on our Website. We collect aggregate information on which pages of our Website that users access or visit.

Data Collected Through Voluntary Submissions
We collect and store any information that you voluntarily submit to us, including via registration. If you identify yourself by sending us an email, we collect and store your email address and any other information you provide in your email. As set forth in more detail below, we use this information for internal purposes and to contact you and/or send you information, including marketing information about our products (please see below). 

TYPES OF DATA COLLECTED
Information you provide to us:
While using our Website, we may ask you to provide us with certain information that can be used to contact, identify, or locate you. Information that you may provide includes, but is not limited to:
  • Email address
  • First name and last name
  • Phone number
  • Address, City, State/Province, ZIP/Postal code,
  • Country
You are not under any obligation to provide this information. However, if you withhold requested information, we may not be able to provide certain services to you.
We may use your information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you via email, post or telephone. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any communication we send or by contacting us using the information below.
Location Data
We may use and store location data to send you information about our products and coupons in the postal mail and email, to help you locate retailers of our products, to provide features of our Website and to improve and customize our Website.You can enable or disable location services when you use our Website at any time, through your device settings.

Automatic Data Collection and Tracking
Usage Data
We also collect certain passive tracking data concerning how the Website is accessed and used (“Usage Data”). This Usage Data includes information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Website that you visit, the times and dates of your visits, the time spent on those pages, and diagnostic data.

Tracking Data & Cookie Policy
We use cookies and other online tracking technologies to understand visitor activity on our Website, and to hold certain information about your visits to help improve your experience while using the Website.A cookie is a text file sent by a web server and placed on your computer by your web browser. Cookies can be divided into two different types: session and persistent. Session cookies differ from persistent cookies primarily in that session cookies are temporary and expire and are typically deleted when you close your browser. Persistent cookies, in contrast, remain stored on your computer after you close your browser until they are deleted either because they expire or you delete them. 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, part of the Website may function differently and not as well and you may not be able to use some portions of our Website.The types of cookies we use are:
  • Session Cookies. We use session cookies to operate our Website and for security purposes.
  • Persistent Cookies. We use persistent cookies to remember your preferences and various settings.
Cookies are often used in conjunction with other Internet technologies, such as web beacons, to understand behavior on the Internet. For example, Imalac uses cookies in conjunction with web beacons, which are small sections of code that we may place in our Website to understand the number of unique users that have visited a specific page.

We use session cookies in connection with our Website, for security purposes, and to provide you with customizations of your experience, such as highlighting your recently viewed items, to detect and remember your region and language preferences, and track your activities on the Website. We also use cookies that persist over time, including to ensure that you are directed to the correct regional version of our Website and in connection with “tailored advertising” (which associates a user’s activity and interest information, demographic information, geographic information, and similar information with a browser cookie in order to provide more useful and relevant advertising). We may use the services of certain third parties in connection with these cookies.

None of these cookies is strictly necessary to access our Website. You may reset your browser to refuse all cookies or to allow your browser to alert you when a cookie is set. However, certain parts of the Website may function differently and not as well and you may not be able to use some portions of our Website.  Unless you have adjusted your browser setting so that it will refuse cookies, our Website will issue cookies when you log on to the Website. For more information about how to manage your cookies preferences, you should use the “help” menu of your web browser or explore the customer support sections of your web browser.

In addition, you may also refuse or remove persistent targeting cookies by “opting out” of “interest-based”/“online behavioral”/“tailored” advertising via third-party advertising cookies at the following sites:
Please note that you need to configure each browser on each device that you use if you wish to opt-out or block some or all cookies. If you buy a new device, upgrade or change web browsers or delete your opt-out cookies, you will need to perform the opt-out process again. In order for opt-out processes to work, your browser must be set to accept third-party cookies.  Additional information about cookies is available at http://www.aboutads.info/consumers#cookies and http://www.youronlinechoices.com.

Data Collection and Use
Imalac uses the information collect for internal business and various other purposes, including:
To respond to your requests including, concerning our products
To help you locate retailers of our products
To provide customer support
To provide goods or services to you
To improve and customize our Website
To provide and maintain our Website
To notify you of changes to our Website
To gather analysis or valuable information so that we can improve our Website
The day-to-day running and management of the business and the services offered to customers
To monitor the usage of the Website
For fraud prevention and detection and to comply with applicable laws, regulations or codes of practice
To share personal information with third parties that acquire or are interested in acquiring all or part of our assets or shares or that succeed us in carrying on our business.
To enforce or defend our rights, ourselves or through third parties to whom we delegate such responsibilities
To investigate and resolve complaints and manage regulatory matters, investigations and litigation
To share data with police, law enforcement, tax authorities or other government agencies where we have a legal obligation and to comply with applicable laws, regulations or codes of practice
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 inquired about unless you have opted not to receive such information
To allow you to participate in interactive features of our Website when you choose to do so
For tailored advertising on third party sites either because of the website you are viewing, or based on your interests which we have inferred from your information. 
Legal Basis in the EU (with respect to “personal data”):
We have a legitimate interest to respond to your requests and inquiries for ongoing business administration
To manage and perform our contract with you We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient as we can be
We have a legitimate interest to improve the quality and efficiency of the services offered to you 
We have a legitimate interest to manage our business including for legal, personnel, administrative and management purposes and for the prevention and detection of crime provided our interests are not overridden by your interests
To comply with our legal or regulatory obligations
We have a legitimate interest to manage our business including for legal, personnel, administrative and management purposes
To manage and perform our contract (the Terms) with you
To comply with our legal or regulatory obligations
To manage and perform our contract (the Terms) with you
To comply with our legal or regulatory obligations
If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent. If you wish to stop receiving marketing communications from us you can unsubscribe via the link at the bottom of the relevant marketing email or contact us using the contact details below
We have a legitimate interest to carry out direct marketing
With your consent if required by applicable law which you can withdraw at any time
With your consent, if required by applicable law. If you no longer wish to see tailored advertising, you can amend your cookie preferences (see section: TRACKING DATA AND COOKIE POLICY above).
Right to Object: As mentioned above, you have a right to object to processing of your personal data where that processing is carried out for our legitimate interest or for direct marketing.

Analytics
We may use third-party technology providers to monitor and analyze the use of our Website. This includes Google Analytics – for more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

Behavioral Remarketing
Imalac uses remarketing services to advertise third party services to you after you visit our Website. We and our third-party vendors use cookies and other online tracking technologies on our Website and in third party services (including in emails and advertisements) to track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you on the Website and in third-party services or third-party devices after you have left the Website.

For instance, we serve ads on and through third party services, such as Facebook and Google, that are targeted to reach people (or people similar to people) who have visited our Website who are identified in one or more of our databases (“Matched Ads”). For example, we use Facebook Custom Audiences to serve Matched Ads. This is done by us uploading a customer list to the third party service or incorporating a pixel from the third party service on our Website, and the third party service matching common factors between our data and their data. “Matched Ads” may be considered a kind of tailored advertising. To opt-out of us using your data for Matched Ads, please contact us as set forth in the “To Contact Us” section and specify that you wish to opt-out of Matched Ads. We will request that the applicable third party services not serve you Matched Ads based on information we provide to it. You may also contact the applicable third party services to opt-out. We are not responsible for such third party services’ failure to comply with the opt-out instructions.

Your Choices
If you do not want us to contact you or send you information by email, postal mail and/or telephone, please let us know by sending an email to us at the address listed below. If you would like to change any of the information that you have provided to us, please notify us by sending an email to us at the address listed below. If you would like us to remove you from our database, please notify us by sending an email to us at [email protected].

Retention of Personal Information
Imalac will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. The criteria used to determine the retention periods include: (i) how long the personal information is needed to provide the services and operate the business; (ii) the type of personal information collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes). Imalac 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 Website, or we are legally obligated to retain this data for longer time periods.

Transfer of Data
Your information, including personal 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.If you are located outside of the United States and choose to provide information to us, please note that we transfer the data, including personal information, to the United States and process it there.

By providing us with your personal data, you consent to this transfer to the U.S., which your country may not consider to provide for adequate privacy protections. You may withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.Imalac 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 with respect to the security of your personal data.

Sharing of Data
We use the information collected for internal purposes, including to measure the number of visitors to the different sections of our Website and to determine how best to enhance the usability of our Website, and for commercial purposes.  We may share your information with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, processing credit card payments, providing customer service and marketing assistance, performing business and sales analysis, supporting our Website functionality and supporting other features offered through our Website. These service providers may have access to personal information needed to perform their functions but are generally not permitted to share or use such non-aggregated information for any other purposes. We do not sell personal information of consumers.

Disclosure for Law Enforcement
Under certain circumstances, Imalac may be required to disclose your information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements
Imalac will disclose your information in the good faith belief that such action is necessary to:
  • To comply with a legal obligation
  • To protect and defend the rights or property of Imalac
  • To prevent or investigate possible wrongdoing in connection with the Website
  • To protect the personal safety of users of the Website or the public
  • To protect against legal liability
Security of Data
Data security is important to us, but please keep in mind that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect information, we cannot guarantee its absolute security.

Your California Privacy Rights under the California Consumer Privacy Act (CCPA)
If you are an individual who is a resident of California (a California “consumer”), you have the following rights under the California Consumer Privacy Act, which went into effect on January 1, 2020, with respect to your “personal information” (as defined by CCPA):

Right to Know
You have the right to request that we disclose to you, following your “verifiable consumer request”:
  • The categories of personal information we have collected about you
  • The categories of sources from which the personal information is collected
  • The business or commercial purpose for collecting personal information
  • The categories of third parties with which we share personal information
  • The specific pieces of personal information we have collected about you
  • The categories of personal information about you that we disclosed for a business purpose
  • If we sell your personal information (to our knowledge, we do not sell personal information of California consumers – see below in this section under the heading “Disclosure of Personal Information”):The categories of personal information that we sold about you
  • The categories of third parties to which your personal information was sold, by category or categories of personal information for each category of third parties to which the personal information was sold
  • The business or commercial purpose for selling personal information 
Right to Delete
You have the right to request that we delete, following your “verifiable consumer request”, the specific pieces of personal information we have collected about you.
  • Categories of personal information we collect
  • Specific pieces of personal information we have collected about you
  • Categories of sources from which we collect personal information
Right to Non-Discrimination
  • We may not discriminate against you because you exercise any of your rights under CCPA, including by:
  • Denying goods or services to you
  • Charging you different prices or rates for goods or services, including through 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
Methods of Submitting Requests
If you are a California consumer, you may submit requests to exercise your “right to know” or your “right to delete” by email to: [email protected]

CCPA Personal Information 
We collect (and during the last 12 months have collected) the following categories of personal information, from the following categories of sources, and for the following business or commercial purposes:  
Categories of ​Personal Information
Categories of Sources
Business/Commercial Purposes
Identifiers (such as a real name, postal address, email address, an online identifier, or an internet protocol address)
We receive such information directly from consumers (such as when they complete a purchase on our Website) and/or from third-party vendors (such as vendors that use cookies and other online tracking technologies on our Website and in third-party services (including in emails and advertisements) and third-party data providers)
For our operational and commercial purposes, including to manage, perform, and administer our contracts and relationships with consumers,to contact consumers, and/or to send information (including marketing information about our products) to consumers, and to engage in tailored advertising



Commercial information (such as records of the products a consumer purchased)
We receive such information directly from consumers (based on the purchase activities of those consumers on our Website) and/or from third-party vendors (such third-party data providers
For our operational and commercial purposes, including to manage, perform, and administer our contracts and relationships with consumers, to engage in tailored advertising, and to manage our supply chain (including with respect to buying decisions)



Internet or other electronic network activity information (such as browsing history, search history, and information regarding interactions with our Website and our advertising)
We receive such information from third-party vendors, including ad platforms and vendors that use cookies and other online tracking technologies on our Website and in third-party services (including in emails and advertisements)
For our operational and commercial purposes, including to engage in tailored advertising and to manage our supply chain (including with respect to buying decisions)



Geolocation data
We receive such information directly from consumers (such as when they complete a purchase on our Website) or from third-party vendors (such as third-party data providers)
For our operational and commercial purposes, including to manage, perform, and administer our contracts and relationships with consumers,to contact consumers and/or to send information (including marketing information about our products) to consumers



Inferences (drawn from any of the other categories of personal information of the information to create a profile about a consumer reflecting, for example, a consumer’s product preferences)
We receive such information from third-party vendors, including vendors that perform analytics and remarketing services for us
For our operational and commercial purposes, including to engage in tailored advertising
​Disclosure of Personal Information
We disclose (and during the last 12 months have disclosed) each of the above categories of personal information for a business purpose with our authorized service providers that perform certain services on our behalf, including fulfillment, shipping, and handling providers, payment service providers, data analytics providers, technology service providers, and advertising and marketing service providers and platforms. These services may include fulfilling orders, processing credit card payments, providing customer service and marketing assistance, performing business and sales analysis, supporting our Website functionality and supporting other features offered through our Website, and providing advertising and marketing services (including delivering tailored advertising and email marketing campaigns, and analyzing and improving the effectiveness of our advertising and marketing). We do not sell personal information of California consumers.

Your California Privacy Rights under “Shine the Light”
California’s “Shine The Light” law permits certain individuals who are California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not distribute your personal information to outside parties for their direct marketing without your consent, except as provided for in this Privacy Policy. For more information, please email us at [email protected], with “California Shine the Light Privacy Request” in the subject line, and your full name, email address, postal address and specific services you have used in the body of your email.

Your Data Protection Rights Under the European General Data Protection Regulation (GDPR)
Data protection laws in Europe require a “lawful basis” for processing “personal data” (as defined by GDPR). If you are in the European Economic Area (EEA), Imalac’s legal basis for collecting, using, and disclosing the personal information described in this Privacy Policy will depend on the personal data we collect and the specific context in which we collect it.If you are in the EEA and certain requirements are fulfilled, you have the following data protection rights:The right to access, update or to delete your personal data. 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.The right of rectification. You have the right to have your personal data rectified if that information is inaccurate or incomplete.The right to object. You have the right to object to our processing of your personal data if we have no legitimate reasons to do so, and to direct marketing.The right of restriction. You have the right to request that we restrict the processing of your personal data (i.e., we would need to secure and retain the personal data for your benefit but not otherwise use it). The right to data portability. You have the right to be provided with a copy of your personal data in a structured, machine-readable and commonly used format (or have this transferred to a third party). The right to withdraw consent. You also have the right to withdraw your consent at any time where Imalac relied on your consent to process your personal data.If you wish to exercise one of the above-mentioned rights, please send us your request via email to: [email protected]. Please note that we may ask you to verify your identity before responding to such requests.You also have the right to complain to a data protection authority about our collection and use of your personal data. We would, however, appreciate the opportunity to address your concerns before you approach a data protection authority, and would welcome you directing an inquiry first to us at: [email protected].

Links to Third-Party Websites and Third Party Features 
There are a number of places on our Website where you may click on a link to access another party’s website that does not operate under this Privacy Policy. For example, if you click on an advertisement or a search result on our Website, you may be taken to a third party website that we have no ownership or control. These third-party websites may independently solicit and collect from you and in some instances provide us with information about your activities on those websites. 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. We may allow you to connect our Website to a third-party service or offer portions of our Website through a third-party service (“Third Party Features”). If you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature, and you should carefully review the third party’s privacy policy and terms of use. Some examples of Third Party Features include the following: 

Liking, Sharing, and Logging-In
We may embed a pixel or SDK on our Website that allows you to “like” or “share” content on, or log-in to your Imalac account through, third-party services, including social networks such as Facebook. If you choose to engage with such a third-party service through our Website, we may collect any information you have authorized the third-party service to share with us (such as your user ID, billing information, public profile information, email address, birthday, friends list, and other account and profile data). Likewise, if you choose to engage with such a third-party service through our Website or visit our Website while logged in to that third-party service on your device or through our Website, the third-party may receive information about your activities on our Website and be able to associate that information with information the third-party already has about you.

Brand Pages and Chatbots
We may offer our content on social networks such as a Facebook and Twitter. Any information you provide to us when you engage with our content (such as through our brand page or via our chatbot on Facebook Messenger) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Website on a third-party service (e.g., by using a hashtag associated with Imalac in a tweet or post), we may use your reference on or in connection with our Website.

Voice-Activated Skills
We may offer skills through Alexa and other voice-activated platforms, and use the voice processing and other technologies discussed in the section entitled “Automatic Data Collection and Tracking” above. Any information you provide to us when you engage with our skills is treated in accordance with this Privacy Policy.

Children’s Privacy
Our Website is not intended for children under the age of 13.

We do not knowingly collect personal information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we will take steps to remove that personal information from our servers.

Changes to this Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

To Contact Us
If you have any questions about this Privacy Policy or our information-handling practices, or if you would like to request information about our disclosure of information to third parties, please contact us by email or postal mail as follows:

Imalac, Inc.
9700 S Dixie Hwy
Unit 810
Miami, FL 33156
[email protected]

With respect to the EEA personal data we collect, Imalac is the controller responsible for your personal data. As the controller, we determine the purposes for which and the manner in which any personal data are, or are to be, processed with respect to the Website. If you have questions regarding this Privacy Policy or our Website privacy and data protection practices, or if you would like to contact our data protection representative, our email address is [email protected].

For specific California privacy inquiries, please see the contact information set forth above under “Your California Privacy Rights under the California Consumer Privacy Act (CCPA)” and Your California Privacy Rights under ‘Shine the Light’”.

LAST UPDATED: DECEMBER 1, 2019