1. HOW DO WE COLLECT INFORMATION?
We collect and store information that you voluntarily provide to us as well as data related to your use of the Platform. Below is a more specific list of the personal information we collect and how we use it with your consent. You may be asked additional questions regarding items on this list to ensure we have your consent to collect and use your personal information for specific purposes.
A. Information You Provide
- Shopify Newsletter/Email Waitlist: When you voluntarily provide us with your email address, we collect your email address from which your identity is or may be discernible.
- Account Creation: If you establish an account on the Platform, we may collect your name, email address, billing address, and other information to support your use of the Platform.
- Partner with Hue: If you are an enterprise / business customer (as opposed to an individual user) seeking to partner with Hue, we will require that you provide us with your name, company name, email address, address, and general reason for interest in a partnership.
- Hue Beauty Early Access: To be considered for early access to Hue and the Skin Twin matching system, we require your name, email address and, if you are 18 years or older and wish to be considered to be featured on Hue’s Platform (a “Content Creator”), any social media usernames you intend to connect with Hue.
- Content Creator: To be considered to be featured as a Content Creator on the Platform we require that you submit your name, email address, phone number, preferred pronouns, age, geographic location, Instagram handle, all other social media usernames you intend to connect with Hue, and favorite cosmetic foundation details.
- Support: If you send messages through our contact form, or provide information to our sales or support teams, we collect your name, email address, and other information to reasonably provide the support you have requested.
B. Automatically Collected Information
C. Third Party Services & Partners
To the extent you use a third party service to intact with our Site or Services, such as our credit card payment processor (currently Stripe), integration with social media or other communications platforms (such as Slack), and through our business , personal data will be collected by those providers and governed by their respective privacy policies.
2. HOW DO WE USE INFORMATION WE COLLECT?
Our primary purpose in collecting information is to provide you the Platform. We may use the information you provide to us for other purposes as follows:
- Support the Platform: We may use the information you provide us to provide any customer support you request, including troubleshooting problems, and monitor such requests, and to inform you about updates to the Platform.
- Improve the Platform: We may use the information you provide us to customize, measure, and improve the Platform, including through data analysis, testing, research, statistical and survey processes.
- Enforce Rights: We may use the information you provide us to enforce your and our rights (including payment for the Platform) and to protect you against fraud.
- Marketing Purposes: We occasionally may contact you about new product and features. You may remove your name from our mailing lists to stop receiving these emails. We also may share your email address with our partners and affiliates.
If you have any questions regarding the foregoing, or our privacy practices, you may contact us at email@example.com
3. CAN WE USE DE-IDENTIFIED INFORMATION?
In addition to the uses of personal information above, we may remove the personally identifiable parts of your information to create de-identified forms (“De-identified Information”). De-identified Information may be compiled with other data in aggregated forms. We may use this De-identified Information in the following ways:
- Disclosure for Business Purposes: We may also license, sell or otherwise share De-identified Information with clients, partners, investors and contractors for any purposes related to our business practices.
- Platform Improvement: We may use De-identified Information for product improvement including to the Platform as well as share it with third parties to evaluate their products or services.
- Research: We may use De-identified Information for research whether scientific, marketing, or business in nature. This research may be made public through publication such as within a scientific journal.
4. HOW DO WE SHARE THE INFORMATION WE COLLECT?
We do not sell, rent, trade or otherwise transfer personally identifiable information to third parties who are not our affiliates or business partners without your consent to do so. We may, however, disclose personally identifiable information: to our affiliated companies - including strategic alliance affiliates, carriers, third party service providers and/or agents, as reasonably necessary to provide you with the Platform you have requested; as required by law or legal process; in response to lawful requests for information by governmental agencies, such as law enforcement authorities, authorized to request such information; to enforce our contractual agreements, including investigation of potential violations thereof; to help detect and prevent potentially illegal acts and violations of our policies and to otherwise protect our interests; to help detect and prevent harm to persons or property or otherwise to protect public safety; to third parties that perform functions on our behalf, including, but not limited to, third parties that host or operate our Platform, analyze data, perform email list management services, provide customer service, or provide public relations and marketing services; and to vendors of products and services that are offered through the Platform.
We are not limited in our use of De-identified Information or non-identifiable aggregate information about our users (such as the number of users on the Platform and the geographic distribution of our users). As such, in no way to limit the foregoing, we may share aggregate (non-personally identifiable) information with certain third parties such as advertisers, industry organizations, and prospective affiliates.
We do not enable third parties, except for certain of our subcontractors, to collect information directly from users while they interact with the Platform. Our subcontractors only collect and use information at our direction and only to support the functioning of the Platform and to perform analytics. Our subcontractors may not share this information with third parties.
As with any other business, it is possible that in the future we could sell or buy subsidiaries or business units. In any such transaction, as well in the event all or substantially all of our assets are acquired by a third party, personal information of our users will generally be one of the transferred assets. We reserve the right to include your personal information, collected as an asset, in any such transfer to a third party.
Information collected by or sent to us may be stored and processed in any country in which we and our affiliates, subsidiaries, or service providers maintain facilities. We reserve the right to transfer your personal information outside of the country where you reside and/or from which you use our Platform. By using our Platform you consent to any such transfer of information outside of your country.
5. HOW LONG IS YOUR PERSONAL INFORMATION KEPT BY US?
6. WHAT ARE COOKIES AND HOW DO WE USE THEM?
7. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We follow commercially accepted industry standards to protect the personal information submitted to or collected by us, both during transmission and once we receive it. While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the internet, or method of electronic storage, is 100% secure and we cannot guarantee its absolute security. In the event of an inadvertent disclosure of your personal information, we will take all commercially reasonable steps to limit and remedy the disclosure as required by the applicable law. In light of the foregoing, your use and access of the Platform is at your own risk. If you have any questions about security of our Platform, please contact us in the manner set forth under the heading “HOW CAN YOU CONTACT US?” below.
8. CAN CHILDREN USE THE PLATFORM?
The Platform is intended for the use of users who are at least 18 years of age. The Platform is not directed to persons under the age of 18. We do not knowingly collect or solicit information from, market to or accept services from persons under the age of 18 years old. If we become aware that a person under the age of 18 has provided us with personal information, we will take steps to remove such personal information.
9. HOW FAR DOES OUR RESPONSIBILITY EXTEND?
10. HOW CAN YOU ACCESS OR AMEND YOUR PERSONAL INFORMATION (RIGHT OF OPT-OUT, ACCESS AND CORRECTION)?
We will make all reasonable efforts to accommodate requests to delete personal information unless it is required by law or for any lawful business purpose, and always will delete any personal information that we are required by applicable law to delete at your request.
You can help us maintain the accuracy of your information by notifying us of any changes to your personal information as soon as possible. Your rights to access, change, or delete your personal information are not absolute. We may deny you such rights when required by law or if the request would likely reveal personal information about a third party.
To request opt-out, review, modification or removal of personal information, you should submit a written request to us at: firstname.lastname@example.org
You have the right to view, correct, complete or remove your personal information. Upon and subjection to verification of your identity, we will respond to requests to view, correct, complete or remove your personal information within a reasonable time.
11. YOUR CALIFORNIA PRIVACY RIGHTS
Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights relating to collection, use, and sharing of their personal information for companies that do a minimum amount of business in or with California residents.
We currently do not meet the minimum necessary requirements to be subject to the CCPA. However, we also do not sell your personal information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale if required by law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your personal information.
If you are a resident of California, you have the right to request to know what personal information has been collected about you, and to access that information. You also have the right to request deletion of your personal information, though exceptions under the CCPA may allow us to retain and use certain personal information notwithstanding your deletion request. You may also send your request to us by contacting us at the address below under the heading “HOW CAN YOU CONTACT US?”.
Separate from the CCPA, California’s Shine the Light law gives California residents the right to ask companies what personal information they share with third parties for those third parties’ direct marketing purposes. We do not disclose your personal information to third parties (not including affiliates or business partners) for the purpose of directly marketing their goods or services to you unless you consent to such disclosure. If you have any questions regarding this policy, or would like to change your preferences, you may contact us at the address listed below.
Also, California Civil Code Section 1798.83 permits customers who are California residents and who have provided us with “personal information” (as that term is defined in Section 1798.83) to request certain information about the disclosure of that information to third parties for their direct marketing purposes. If you are a California resident with questions regarding this, please contact us in the manner set forth under the heading “HOW CAN YOU CONTACT US?” below.
12. CALIFORNIA DO NOT TRACK SIGNALS.
We do not currently take actions to respond to “Do Not Track” (DNT) signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a DNT standard once one is created. For information about DNT, please visit: www.allaboutdnt.org.
13. CAN EUROPEAN USERS USE THE PLATFORM?
In general, under the GDPR you may:
- request access to your Personal Data
- have incomplete or incorrect data corrected
- have your Personal Data deleted
- suspend or restrict our use of your Personal Data, or withdraw your consent
- request a copy of your Personal Data
- complain to a supervisory authority if you believe your rights under the GDPR are not being respected
Should you request a copy of your Personal Data, we will supply to you a copy of it. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. Should you request the deletion of your Personal Data, we will generally do so as soon as practicable, although your right to have your Personal Data deleted is subject to exceptions, such as, for example, compliance with a legal obligation or for the establishment, exercise or defense of legal claims.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
Contact us, through [[TITLE AND CONTACT INFO]], if you have concerns regarding your Personal Data, or wish to exercise any of these listed rights.
Note that, if you are in the EEA, we may transfer your Personal Data outside of the EEA, including to the United States. By way of example, this may happen if your Personal Data is transferred to our servers located in a country outside of the EEA. These countries may not have similar data protection laws to the EEA. By submitting your Personal Data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy.
16. HOW CAN YOU CONTACT US?