Effective date:  09/01/2019

This Privacy Policy explains the privacy practices of ICM Factory Direct, Street No.2, Binh Duong Industrial Zone, Di An, Binh Duong, VietNam 700000 (“ICM Factory Direct”, “we”, “us”, or “our”). This Privacy Policy applies to information collected through the websites: www.ICMFactoryDirect.com and https://app.ICMFactoryDirect.com; and any ICM Factory Direct apps (collectively, the “Platform”)(“Website(s)” and “site(s) are used interchangeably).  If you have any questions about this Privacy Policy, contact us at Info@icmfactorydirect.com.

What information do we collect about you?

We collect information provided by you, including contact information, the login and password you use to access the Platform, body measurements captured by one of our scanners and/or apps, credit card information, and all information from third-party services that you link to your ICM Factory Direct account (“Personal Information”). We may also collect information about computers and devices used to access the Platform, including the location of such computers and devices. We use beacons, cookies, and other tracking technologies to collect user information.

We collect information voluntarily provided to us, including information your computer, mobile phone, console, tablet or other devices (collectively, “Device”) or web browser automatically provides. Cookies and other tracking technologies allow the Platform to perform better for you and for our advertising purposes. You can opt out of the use of cookies, however, certain features of the Platform will not work correctly if opt-out. 

Information You Provide to Us: When you use the Platform, we, or our third-party service providers (acting on our behalf), collect “Personal Information” (i.e. information that, on its own or when combined with other information, can be used to identify you) that you provide to us, including but not limited to your first and last name, your gender, your personal image (whether through use of our scanners or photo apps), email address, your geographic location, telephone number(s), mailing address, your age, birth date, profile, weight, biometric data, and payment card information.

We collect information from you when you register to create an account on the Platform, inquire about the Platform, use the Platform to update your account information, purchase products through the Platform, use any of our products or services, participate on a blog post by commenting or otherwise, sign up for a subscription, voluntarily enter into promotions we may offer from time to time, sign up for email updates or to receive our newsletter and/or advertisements, and/or when you are referred to us by a friend or through a marketing promotion.

Information Stored by Third Parties: You may also choose whether to provide us with access to Personal Information stored by third-parties including social media sites and health sites, including Apple HealthKit, Google Fit, FitBit, MyFitnessPal, etc., including sites that may be created later. The information we may have access to varies by third party site and is controlled by the privacy settings of, and your authorization(s) on such third-party site(s).

Information about Others: You may choose to provide us with another person’s contact information in order to invite them to join the ICM Factory Direct Platform. We use this information to contact and, if necessary, remind that person that he or she has been invited to join the ICM Factory Direct Platform. All invitees must opt-in to receive further invitations and communications from ICM Factory Direct.

Information Collected Automatically:  When you interact with the Platform, a variety of technologies automatically collect information about how you access and use the Platform (“Usage Information”). This data provides us with actionable business insight, such as how many visitors visit a specific page or product listing on the Platform, how much time they spend on that page, and which links they “click,” if any. This data helps guide our choices when we update our website, enabling us to keep our content and offers interesting and relevant to our visitors’ interests. 

Usage Information includes your IP address or other unique identifier(s) for your Device, your Device type, the type of browser software and operating system you are using to access the Platform, the web page(s) you have accessed and when you accessed them, product and network usage logs for error detection and support.

Cookies and Pixel Tags: Technologies used on the Platform to collect Usage Information include but are not limited to cookies, mobile analytics software, and pixel tags.  Cookies may be used to associate you with social networking sites and enable interaction between your activities on the Platform and your activities on such social networking sites, if you so choose.  We or our vendors, may place cookies or similar files on your Device to facilitate site navigation and to personalize your experience while engaging with our Platform (i.e. allowing us to select which content, ads or offers are most likely to appeal to you, based on your interests, preferences, location, and/or demographic information).  A pixel tag may tell your browser to get content from another server.  

Google Analytics: We reserve the right to use a tool called “Google Analytics” to collect information about your internet use, including how often you visit our site, the pages you visit on our site, and what other websites you may have visited before coming to our website. Google Analytics provides us with insights regarding how the Platform is used and it helps us improve the quality and relevance of our products and services. Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site – the cookie cannot be used by anyone but Google. To opt-out of Google Analytics, you can use Google’s opt-out tool found here: https://tools.google.com/dlpage/gaoptout.

How do we use your Personal Information?

Orders / Recommendations: We use your information to process and fulfill your orders and requests, and to recommend custom products and services based on your unique measurements. Your information is used to help us provide our products, use of the Platform, and ultimately to deliver your purchases to you.

Marketing: To send you emails, newsletters and other marketing communications via the internet, mail, and/or telecommunications networks, in order to inform you about offers we think you will find valuable.

Security: To protect the security of our Platform, to enforce our terms and conditions, and to conduct market research and audience analysis, to better understand who our ideal customers are and which products and services they would like us to provide to them. We may use your personal information to customize content and advertising on the Platform, and to recognize you as a return visitor. We also may provide certain information to our business clients.

To perform our responsibilities under a contract we have with you.  For example: If you purchase goods or services through the Platform, we will need to use your Personal Information to process your order and to enable delivery. We will use your body measurements for the purposes for which you were scanned (for example, to recommend products to you). We may also do analyses of our customers based upon their body measurements. 

When we or our business clients have a legitimate interest in such use. For example: To prevent fraud and/or protect the security of the Platform, to enforce our terms of service, communicate updates and improvements, conduct market research and/or Platform analytics, develop and optimize our products and services, send you marketing communications about products and services we offer that are similar or related to products and services you have purchased from us, to provide our business clients with analytics, artificial intelligence, recommendations, audience segments regarding consumers’ use of the Platform or our products and services, and to comply with our legal obligations.

With your consent.  For example: We send marketing communications to you only if you consent to receive them. We do not share your Personal Information with third parties for their direct marketing purposes without your consent. With your consent, we use your information to personalize your ICM Factory Direct experience, including to tailor content, advertisements, and offers we present to you such as custom product recommendations including clothing, sports apparel, shoes, headwear, accessories, etc. 

Why do we use your Personal Information?

In order to satisfy our contractual obligations to you. When you have consented to these uses, or otherwise, in connection with our business. When we or our business clients have legitimate business interests in engaging in activities which require the use of your personal information, and it may not be practicable to obtain your consent. We ensure your rights are protected by notifying you of use, informing you of your rights, and strictly limiting the amount of personal information we use to only what is required to fulfill these purposes.

Who do we share your Personal Information with?

Other ICM Factory Direct businesses: We may share your Personal Information with our affiliates where appropriate under applicable law. Other ICM Factory Direct businesses (our “Affiliates”), when relevant, use Personal Information for the purposes described in this Privacy Policy, where this is acceptable under applicable law.

Business Transfers: We will share your Personal Information if we are acquired by, or merge with another company, or otherwise reorganize our business. If any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to relevant third parties.

Third Party Service Providers: We use third parties for Platform hosting, data analytics, email, payment processing, digital marketing, customer service and other services. These third-party service providers will access your Personal Information, when the information is necessary for them to perform their duties, in order to assist us in providing these services to you.  

While accessing our Platform, you may be presented with an opportunity to opt-in to receive information and/or marketing offers from a third-party. If you use the social sharing features available on the Platform, your information may be shared with your social network friends or groups. If you consent to having your Personal Information shared with a third-party, the Personal Information you disclose will be subject to the privacy policy and business practices of that third-party.

With Third-Parties, Where Necessary for Legal Reasons: We will transfer and disclose your Personal Information to third-parties when we are required to do so by law, to comply with legal process served upon us, to ensure you are complying with our terms of use and/or other policies, to investigate possible fraud, or to investigate or rectify any technical or security issues relating to the Platform.

Third-Party Links and Services: We link to websites controlled by other parties; we are not responsible for the privacy practices of such websites.  If you link your ICM Factory Direct account with your account on a third-party website or platform, ICM Factory Direct will also have access to the information you share with that third-party.

The Platform and some of our email communications contain links to third-party websites.  We do not control or endorse these third-party sites. These third-party sites may collect personal information about you, and they are not governed by this privacy policy.  We recommend that you review the privacy policy of any site that you access through the Platform.

Advertising

ICM Factory Direct may use information obtained from your use of the Platform or our products and services to determine what kind of content we believe may be of interest/relevant to you. You can decide if you want to see advertising based on your interests. If you opt-out, you will still be shown ads, only they will be less relevant to you.

ICM Factory Direct may use third-party advertising network providers to help us present ads on the Platform. We may also engage other third-party service providers to provide us with analyses regarding the use of the Platform.  Such providers may place and access pixel tags, cookies, and/or similar technologies on your Device in order to present you with ads or other content personalized to your interests based on your history of browsing on the Platform and other sites you have visited. The use of such pixel tags, cookies, or other similar technologies by these third-party service providers is subject to their own privacy policies.

How long do we keep the Personal Information of our users? We keep user information until we are asked to delete it. Once asked to delete personal information, we will only keep such information as needed to fulfill legal obligations or if it is within our legitimate interests. If you would like to ask us to delete your user information, you can submit a request using the contact information provided at the end of this Privacy Policy.

Your rights and choices: Users are provided with the ability to opt-out of promotional messages and interest-based advertising. Users based in the European Economic Area (EEA), have the right to:

Access the information we have about you and to request that we correct or update it as needed. Request a copy of the information we have about you. Request that we delete the information we have about you. Withdraw your consent to the processing of your information or request that we limit how we use your information.

You may submit a request gm@icmfactorydirect.com.

Contact Us:

Street No.2, Binh Duong Industrial Zone, Di An, Binh Duong, VietNam 700000 

Learn More about ICM Factory Direct’s Privacy Policy

Children: We do not knowingly collect personal information from children.

Transfers of personal information to Vietnam: ICM Factory Direct’s headquarters are in Vietnam where the privacy laws may differ from the laws in your country. We safeguard your Personal Information when it is transferred out of your country using industry standard security measures and contracts.Information collected from you will be processed in Vietnam. The laws of Vietnam may not protect the privacy of your information to the same degree as the protections provided by the laws of your country. You will not lose any rights or choices concerning the use of your Personal Information when it is transferred to Vietnam.

Storage of your personal information: We store your information until you ask us to delete it. Once you ask us to delete your information, we will only keep your information as required to fulfil our legal obligations, enforce our agreements, resolve disputes, or take other actions as permitted by law.

We will retain information from deleted accounts to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, process warranty claims, distribute important product information (such as recall information), enforce our agreements, and take other actions as permitted by law. You may request deletion of your Personal Information by contacting us using the contact details provided at below.

Security Measures: We have security measures in place to protect your information, but we cannot guarantee they will be 100% effective.

We use a variety of technologies and processes including physical, administrative, and technical safeguards for the protection of customer data.  We maintain a private database on our servers for the storage of all information collected through the Platform. We use encryption whenever we receive or transmit sensitive user data.  All transactions completed through the Platform are conducted using 2048-bit Secure Sockets Layer (SSL) encryption.  We take reasonable measures to protect your information from loss, misuse, alteration or destruction, and, where possible, we ask third-parties to whom we may transfer your information to take equivalent steps.  

Email is not a secure form of communication.  Please do not send us your credit card number, social security number or other Personal Information via email.

Your rights and choices: We provide you with the ability to opt-out of promotional messages and interest-based advertising.  If you are in the European Economic Area, you have the right to access the information we have about you, as well as the right to request that we correct it, complete it, erase it, stop using it, or transfer it to you. Submit your request here gm@icmfactorydirect.com. You can opt-out of receiving promotional communications by following the instructions provided in any such promotional communication you receive from us.

Changes to our Privacy Policy: We may change our privacy practices from time to time. If we make any material changes to this Policy, we will provide you with a prominent notification prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Queries or Complaints: If you have any questions or concerns about this Privacy Policy, the Platform, or about our use of your Personal Information, please contact us using the contact details set out below.  If you have complaints about how we use your Personal Information, you may lodge a complaint with the data protection authority in your country. A list of data protection authorities is available here: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

Our Contact Details

You may contact us using the following details:

By email:  gm@icmfactorydirect.com

By post:  Attn: Privacy, ICM Factory Direct, Inc.