│ PRIVACY POLICY │

Effective Date:  May 24, 2018

1.        Privacy Statement.

This Website is owned and operated by Lifecell Cosmetics Ltd. d/b/a Lifecell (“Company” “we” or “our”).  We are committed to advising you of the right to your privacy, and strive to provide a safe and secure user experience.  This Privacy Policy explains how we collect, store and use personal information, provided by you on our website.  It also explains how we collect and use non-personal information.  By accessing and using our website, you explicitly accept, without limitation or qualification, the collection, use and transfer of the personal information and non-personal information in the manner described in this Privacy Policy.  Please read this Policy carefully, as it affects your rights and liabilities under the law.  If you disagree with the way we collect and process personal and non-personal information, please do not use this website. This Policy may be amended or updated at our discretion from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or any changes in applicable law.  Please note that this Privacy Policy addresses only our practices with respect to information we collect in the course of using our services and does not apply to information about you that might be collected by a third-party website or an offering linked to or otherwise accessible from our services. Any information collected, obtained and/or used by any such third parties is subject to the privacy policies of those third parties. We encourage you to review the policies of such third parties.

2.        Personal Data Collection.  The categories of Personal Data we may collect, Control or Process pertaining to you and subject to applicable law, are as follows:

•        Personal Information: Name(s); nickname(s), gender; date of birth; age; marital status;   government   issued identification number(s) ; nationality;  lifestyle  and social   circumstances;   photo images;  signatures; and personal appearance and behavior.

•        Contact Information: address; telephone number; cell phone number, email address; and social media profile details.

•        Financial information: billing address, bank   account   numbers;   credit   card    numbers; debit card numbers, cardholder or account holder name and details.

•        Electronic Identifying Data: IP addresses; cookies; activity logs; online identifiers; unique device identifiers; and geolocation data.

3.        Collection of Personal Information.  We collect Personal Information about you from a variety of sources:

•        Directly from you in the ordinary course of business;

•        Public information or information provided by third parties who collected the same.

•        We collect or obtain Personal Information when you visit our Website purchase products from us. When you visit our Website, your device  and  browser  may  automatically collected and disclose certain information (such as device type, operating system,  browser type,  browser settings, IP address, language settings, dates and times of connecting to a website and other technical communications information), some of which may constitute Personal  Data.

4.        The Legal basis for Collecting and Processing your Personal Data.  We seek to collect or otherwise Process your Personal Data, for the following legal basis:

•        As necessary for compliance with a legal obligation under a contract with you;

•        As necessary for the detection or prevention of crime (including the prevention of fraud) to the extent permitted by applicable law;

•        As necessary for the establishment, exercise or defense of legal rights;

•        We have, in accordance with applicable law, obtained your explicit consent prior to collecting your Personal Data. This legal basis is only  used in relation to collection that is voluntary in doing business with us and is  not used  for collection that is  necessary or obligatory;  or

•        Collection is necessary for reasons of substantial public interest and occurs on the basis of an applicable law that is proportionate to the aim pursued and provides for suitable and specific measures to safeguard your fundamental rights and interests.

6.        Age Limitations. We do not direct our Website or Services to children under the age of 13. We do not knowingly collect information, including personal data, from children or other individuals who are not legally able to use our Website or services. If we obtain actual knowledge that we have collected personal data from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

7.        Purposes For Which we may Use or Process your Personal Data.  The purposes for which we may Process Personal Data are as follows:

•        Signing up new clients; and compliance with our internal compliance requirements, policies and procedures.

•        Maintaining and updating your contact information where appropriate.

•        Marketing and promotional activities.

•        Providing you with information or assistance that you request from us;

•        Providing you with the services requested;

•        Notifying you about changes or additions to our products and services;

•        Monitoring and improving the quality of our services and products;

•        Quality assurance and training purposes;

•        Complying with our legal and regulatory requirements.

8.        Disclosure of Personal Data to Third Parties.  We disclose your Personal Data to other entities for legitimate business purposes including providing products and services to you, in accordance with applicable law.  In addition, we may disclose your Personal Data to:

•        Your representatives as requested or authorized;

•        Our vendors, subcontractors and service providers. We may share your data with our services providers who process your personal data to provide the products or services to us, you or on our behalf. We have contracts with our service providers that prohibit them from sharing the information about you that they collect or that we provide to them with anyone else or using it for other purposes.

•        Governmental, legal, regulatory, or similar authorities, central and/or local government agencies, upon court order, request or where required, including reporting any actual or suspected breach of applicable law or regulation or our contractual agreements;

•         We may disclose the personal information we collect when we believe disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of us, our users, or others.

•        Third party processors located anywhere in the world,

•        Any relevant party, claimant, complainant, enquirer, law enforcement agency or court, to the extent necessary to respond to a court order, or in the exercise or defense of legal rights in accordance with applicable law;

•        Any relevant party for the purposes of prevention, investigation, detection or prosecution of a civil or criminal offence or the execution of civil or criminal penalties, including safeguarding against and the  prevention of threats to public security in accordance with applicable law;

•        In the event that we sell or transfer all or any relevant portion of our business or assets including in the event of a reorganization, dissolution or liquidation, the information is transferred automatically to the new owner;  

•        If we engage a third-party Processor to Process your Personal  Data, the Processor will be subject to binding contractual obligations to: (i)  only Process the Personal Data in  accordance with our prior written  instructions; and  (ii)  use  measures  to  protect  the  confidentiality  and  security  of the  Personal  Data;  together with  any additional requirements  under applicable  law.

9.        International transfer of Personal Data.  Because of the international nature of our business, we need transfer your Personal Data to our servers in the United States and to third parties as noted above in connection with the purposes for which you provided it to us and as set forth in this Privacy Policy.  For this reason, we transfer your Personal Data to other countries that may have different laws and data protection compliance requirements, including data protection laws which are of a lower standard to those that apply in the country in which you are located or are a citizen.

We transfer your Personal Data to other countries on the following basis:

• Adequacy decisions;

• Binding Corporate Rules; or

• Standard Contractual Clauses; or

• Other valid transfer mechanisms.

If you want more information about the safeguards applied to international transfers of personal data, please contact us.

10.        Data Security.  We have implemented appropriate technical and organizational security measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, access in accordance with applicable law.  We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your personal data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. While we are dedicated to securing our systems and services, you are responsible for securing and maintaining the privacy of your password(s) and account/profile registration information and verifying that the personal data we maintain about you is accurate and current. We are not responsible for protecting any personal data that we share with a third-party based on an account connection that you have authorized. You are responsible for ensuring that any Personal Data that you send to us are sent securely.  

11.        Data Accuracy.  We take reasonable steps designed to ensure that:

• Personal Data that we Process is accurate and kept up to date as necessary; and

• Personal Data that we Process which is inaccurate and not necessary to retain is timely

   destroyed and expunged

From time to time we may ask you to confirm the accuracy of your Personal Data.

12.        Data Minimization and Retention.  We take reasonable steps designed to ensure that Personal Data in our systems is limited to that which is reasonably required to be retained in connection with our business purposes including those set out in this Privacy Policy. We may also choose to anonymize certain information you provide to us so that it can no longer be attributed to you if we would like to retain it for longer periods of time.

13.        European Union Citizen Legal Rights (GDPR).  We may transfer your Personal Information to countries other than the one in which you live. In particular, your personal data will be transferred to and processed in