Effective Date: May 21, 2020
1. Information We Collect
When you use our Service, we collect information that identifies you or relate to you as an individual (“personal information”) including:
Photographs: When you upload your photo to the Service we collect and store your photo. Without your photo we cannot provide you with the Service. We do not use your photo to uniquely identify you or distinguish you from other users.
Phone Numbers: We collect your phone number when you send the text message to get access to the Service.
Usage and Tracking Data: We collect information about your device, including your Device ID, IP address, hardware model, geolocation information, operating system and version, device name, mobile application usage data, and aggregated information such as “click stream” information, traffic statistics, page views, and impressions. We do not track customers over time and across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals.
2. How We Use Your Information
To Provide the Service: Once you upload the photo the Service, we will provide you with the suggestion for the best eyebrow shade color.
Research and Development: We use your photo to improve the algorithm of the application. With each additional picture input, our ability to correctly match shades gets better and better. We may further utilize your personal information to improve our online services, analyze usage and interests, identify usage trends, determine the effectiveness of our content and offerings, and to operate and expand our business activities.
Marketing: We may send you follow-up text messages with information about our products or promotions. If we do we’ll make sure to ask for your permission, or give you the option to opt out.
To Enforce our Agreements and Prevent Misuse: To maintain a safe, secure, and trusted environment for you when you use the Service, we use your personal information to make sure our policies, and agreements with you and any third parties are enforced. We actively monitor, investigate, prevent, mitigate, and report fraud, misrepresentations, security breaches or incidents, other potentially prohibited or illegal activities on our Service for your protection.
3. Sharing Information
We do not share your photograph or other personal information except with third parties except as described in this section.
Service Providers : We may disclose your personal information to third-party service providers to provide us with services such as website hosting, and professional services such as information technology services and related infrastructure. We have contracts in place with our service providers to ensure your information is adequately protected and limited in use.
Corporate Transactions or Events: We may disclose your information to a third party in connection with a corporate reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock, including in connection with any bankruptcy or similar proceedings.
Compliance with Law: We may use or disclose your personal information as we deem necessary or appropriate: (1) under applicable law, including laws outside your country of residence; (2) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (3) to comply with subpoenas and other legal processes; (4) to pursue available remedies or limit damages we may sustain; (5) to protect our operations or those of any of our affiliated companies; (6) to protect the rights, privacy, safety or property of us or others; and (7) to enforce our terms and conditions.
We are committed to securing your personal information. We have put in place commercially reasonable physical, electronic, contractual and managerial procedures. However, no system is perfect or can guarantee that unauthorized access or theft might not occur.
5. Notice to California Residents
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018, we collect the following “personal information” categories: identifiers (your phone number and photo), and internet or similar network activity. The sections above explain the reason why and how we collect information, and with who we share the information. Under the CCPA you have the following rights, subject to certain exceptions: (a) the right to request we delete your personal information; (b) the right know the types of information collected, how we use it and who we share it with; (c) the right to opt-out of any sale of your personal information; and (d) the right not to be discriminated against for exercising any these rights. We do not sell any of your personal information. To exercise your rights to know and/or to delete, you will need to submit a verifiable consumer request to us by either: calling us at: 1-800-310-3773; or emailing us at firstname.lastname@example.org. You may also have an authorized agent, a person registered with the California Secretary of State that you authorize to act on your behalf, to make a verifiable consumer request on your behalf.
You are entitled to request and receive once a year, free of charge, a notice from us describing what categories of personal customer information (if any) we shared with third parties or corporate affiliates for their direct marketing purposes during the preceding calendar year. Your written request should be submitted to the address listed in Section 9.
6. Notice to Individuals in Europe
This section only applies to individuals using or accessing our Service while located in the European Economic Area the United Kingdom, or Switzerland (collectively, “Europe”) at the time of data collection. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in Europe.
We are a data controller with regard to any personal information collected from individuals using its Service. We will only contact you if you are located in Europe by electronic means based on our legitimate interests, as permitted by applicable law or with your consent. You can object to direct marketing at any time by emailing us at email@example.com.
Under the EU General Data Protection Regulation, we rely on your consent and/or our legitimate interest to provide our Service, better understand you, to maintain and improve the accuracy of the information we store about you, and to better promote or optimize our Service as the legal basis for our processing described in Section 2, and Sections 3(a) and (b), above. We rely on our legal obligations, the public interest, or in your vital interests as the legal basis for processing described in Section 3(c) Compliance with the Law.
Subject to certain exceptions and limitations, you have the following rights, which you can exercise by contacting us at firstname.lastname@example.org: the right to request to access, correct, port or delete your personal information, object to processing or ask us to restrict processing of your personal information. If you consented to processing, you can withdraw your consent at any time. If you believe we have infringed or violated your privacy rights, please contact us at email@example.com so that we may resolve your dispute directly. You have the right to complain to your local data protection authority about our collection ad use of your personal information.
7. International Transfers
When you access our Service, your personal information may be processed in the United States or any other country in which we, our affiliates, or service providers maintain facilities. The data protection laws in those countries may be less protective than the laws in your jurisdiction. If you do not want your information transferred to, processed, or maintained outside of the country where you are located, you should stop accessing the Service. The transfer of your personal information out of the EEA and Switzerland is necessary for the performance of our contract with you. We also rely on legal transfer mechanisms such as Standard Contractual Clauses or we work with U.S. based third parties that are certified under the EU-U.S. and Swiss-U.S. Privacy Shield Framework.
Our Service is not intended for or directed to children under 16. If we learn we have obtained any personal information about a child under age 16, we will delete that information.
If you have any questions or concerns regarding this policy, please contact us at firstname.lastname@example.org or by mail at Consumer Relations, Anastasia Beverly Hills, LLC, 10635 Santa Monica Blvd, Ste 300 Los Angeles CA 90025.