1. Introduction
Welcome to [Legal Entity Name] ("USE," "we," "us," or "our"). This Privacy Notice explains how we collect, use, and share your personal information through our website, mobile apps, and retail services. By using our Services, you agree to the practices described in this notice.
2. Information We Collect
We collect information that identifies, relates to, or could reasonably be linked to you.
- Identifiers: Real name, alias, postal address, unique personal identifier, IP address, email address, and account name.
- Customer Records: Telephone number, credit/debit card number, and other financial information.
- Characteristics: Age, gender, skin type, hair type, and beauty preferences.
- Commercial Information: History of products purchased, obtained, or considered.
- Biometric Information: If you use virtual try-on tools, we process facial geometry data (biometric identifiers).
- Inference Data: Profiles reflecting your preferences, characteristics, and beauty trends.
3. Third-Party Account Integration & Auto-Updates (Crucial)
If you register via Google, Apple, or other social media accounts:
- Automatic Synchronization: We receive profile data (e.g., name, email, language preference) from the provider. If you update your personal information within your Google or Apple account settings, these changes will be automatically synchronized and reflected in your USE account without any further notice or action required from us.
- Reliability of Data: USE relies on these third-party platforms as the source of truth. You are responsible for maintaining the accuracy of your information on those platforms.
4. How We Use Your Information
- Fulfillment: Processing orders, payments, and deliveries.
- Customer Support: Responding to inquiries and resolving disputes.
- Personalization: Curating beauty recommendations and virtual try-on experiences.
- Marketing: Sending promotional emails, SMS, and push notifications.
- Security & Fraud: Detecting and preventing malicious activities.
5. Sharing and Disclosure of Personal Information (Third-Party Transfers)
We do not sell your personal information for monetary compensation. However, we may "share" or disclose your information to third parties for business and commercial purposes as follows:
A. Service Providers (Data Processors): We transfer information to vendors who perform services on our behalf:
- Logistics: DHL, FedEx, UPS (shipping and tracking).
- Payment Processing: Adyen, PayPal, Stripe (secure transaction processing).
- IT & Cloud: AWS, Google Cloud (storage and maintenance).
B. Advertising & Analytics Partners: We share limited identifiers (IP address, Device ID, Email Hash) with partners for cross-context behavioral advertising:
- Partners: Meta (Facebook/Instagram), Google Ads, TikTok, and Pinterest.
- Your Choice: You may opt-out via the "Do Not Sell or Share My Personal Information" link or through Global Privacy Control (GPC).
C. Legal and Business Transfers: We may disclose data to comply with legal obligations or in the event of a merger, acquisition, or sale of assets.
6. Notice of Financial Incentives (Rewards Program)
Our Beauty Rewards Program offers discounts and points in exchange for your personal information.
- Material Terms: We collect purchase history and contact info to provide benefits.
- Right to Withdraw: You may opt-out at any time by deleting your account.
7. Cookies and Tracking Technologies
We use cookies, pixels, and SDKs to analyze traffic and personalize ads. You can manage preferences through "Cookie Settings" or your browser's GPC signal.
8. Data Retention
We retain your information as long as your account is active or for legal compliance (typically 7 years for financial records).
9. Your State Privacy Rights (CCPA/CPRA, VCDPA, etc.)
Depending on your residency (e.g., California), you have the right to Access, Delete, Correct, and Opt-Out of the "sale" or "sharing" of your data for targeted ads.
10. International Transfers
Your data may be transferred to and processed in the United States, South Korea (for IT operations), or other countries where our service providers are located.
11. Children's Privacy
Our service is for users aged 13 and older. We do not knowingly collect data from children under 13.
12. Contact Us
For inquiries or to exercise your rights: [Privacy Email Address]
How to Exercise Your Opt-Out Rights
To exercise your right to opt-out of the "sale" or "sharing" of your personal information, you may submit a request by:
- Clicking our "Your Privacy Choices" link at the bottom of our homepage.
- Sending an email to us at [Your Email Address].
- Submitting a request through our [Online Request Form Link].
We also recognize Global Privacy Control (GPC) signals. If your browser sends a GPC signal, we will automatically treat it as a request to opt-out for that browser/device.