Last updated February 20, 2020
1. COLLECTION OF INFORMATION.
We collect, process, and use your information when you:
- Register for our Services or sign in to an existing account
- Visit our website(s)
- Access our Services through our application(s)
- Connect to our Services using third-party accounts, such as your email, social media, or payment account(s)
- Contact us for support
- Participate in our shopping or influencer programs
- Enter a sweepstakes, contest, promotion, survey, or poll
Automatically collected information
We and our service providers automatically collect certain information about you through:
- Interaction with our Services
- Cookies and other tracking technologies
- Location-identifying technologies
- Monitoring and analyzing trends, usage, and activities
The types of information you provide may include Personal Information. “Personal Information” means information that can be used to identify you (whether alone or in combination). The Personal Information you may provide to us includes:
- First and last name
- Email address
- Password and login related security information
We may also collect Personal Information and other information based on your use of the Services:
- The nature of the product or service requested or purchased
- How you connect to our Services, such as your IP address, unique device identifiers, device or session IDs, and information regarding the network and connected hardware (e.g., computer or mobile device)
- Browsing, shopping, and purchase history
- Your geolocation
- Click-stream data (the page-by-page paths you take as you browse through our Services)
Information collected through our Apps
If you use our Apps, we may also collect the following information:
- Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
Use of TrueDepth API
Specifically, the API is used to detect user’s face position to provide virtualtry-on of the fashion items to users. It's the only use of that API. The coordinates from the API is not stored in our server and is not shared with any 3rd party.
Use of AR CORE API
Specifically, the API is used to detect user’s face position to provide virtualtry-on to users. It’s the only use of the API. The coordinates from the API is not stored in our server and is not shared with any 3rd party.
2. USE OF INFORMATION WE COLLECT. WE MAY USE INFORMATION ABOUT YOU IN THE FOLLOWING WAYS:
Manage Your Account
If you provide us with Personal Information, we may use it to: (i) process your registration with our Services, including verifying whether your email address is active and valid and enrolling you into our programs; (ii) monitor and manage your account; (iii) track your shopping, deliver you any rewards or payments, and identify opportunities for rewards and/or offers; (iv) send you technical notices, updates, security alerts, and administrative messages; (v) provide you customer service regarding your account and reply to your questions, comments and requests; and (vi) comply with legal and regulatory provisions in force and with the competent judicial authorities in each geographical jurisdiction that the Company operates in. We may also use your information to assess risk and prevent fraud.
Improve Our Services
We may process information through analyzing and monitoring usages and trends and performing statistical analyses to improve our Services and the websites, applications, marketing efforts, and the products and services of our affiliates to provide a better service to you in the future. We may also use this information to adapt Service content to be more likely to be of interest to you.
Provide You Marketing Information
To provide you more personalized offers and/or special offers, discounts and similar information, Company may send you newsletters, rewards, discounts, promotion codes, events, and general information about the Service if you consent. To match your profile and interest, we may create a profile of your preferences and provide advertisements, content or features. You can manage these communications in accordance with Section 4 (Your Choices) below.
Administer Contests, Sweepstakes, and Promotions
From time to time, Company may invite you to enter various contests, sweepstakes, surveys or promotions. If you choose to participate in a contest or promotion, your Personal Information may be used to administer the contest, such as to determine your eligibility for the contest or to award a prize.
3. SHARING OF INFORMATION
We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services or Apps, which will enable them to collect data about how you interact with the Services or Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organization apart from us. They will hold it securely and retain it for the period we instruct.
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
We only share and disclose your information with the following third parties. We have categorized each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.
- Cloud Computing Services
Amazon Web Services (AWS)
- User Account Registration and Authentication
Google Sign-In, Facebook Login and SnapChat Login
- Web and Mobile Analytics
Google Analytics for Firebase
5. YOUR CHOICES
You may in some cases have the option to decline providing us information. However, your choice to not provide information may impact your use of certain features or services. You may unsubscribe or opt out of receiving marketing emails from us by using the unsubscribe link on the footer of our marketing emails, by logging into your account settings, or by using the Contact Us option through the Services. Upon written request, we will provide you with information on whether we hold any Personal Information. We encourage you to maintain the accuracy of the information you submit to us, such as the information you provide us to register for your account. The Services may allow you to access, review, correct, update, and remove or make inaccessible Personal Information you have provided through your account settings. You may provide account updates and changes by logging into your account and changing settings or by using the Contact Us option through the Services. With respect to our mobile and other applications, you can prospectively stop all collection of information by the application by uninstalling the application. You may at any time opt out from further allowing us to have access to your mobile location data by adjusting the permissions in your mobile device. We will make good-faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. We will respond to your requests within a reasonable timeframe.
We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
6. RIGHTS APPLICABLE TO EU USERS
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
Legal basis for using your Personal Information
If you are a visitor from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. For the European Economic Area, there are different legal bases that we rely on to use your Personal Information, namely:
- Performance of a contract. The use of your Personal Information may be necessary to perform the terms and conditions or other policies under which we provide our Services.
- Legitimate interests. We may use your Personal Information for our legitimate interests to improve our Services, security purposes, and fraud prevention, and to share information with our affiliates for internal administration. In such circumstances it is for us to ensure that these interests are not overridden by your data protection interests or fundamental rights and freedoms. If we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), this interest will normally be for to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
Choices under EU law
- Access, correct, update or request deletion of your Personal Information, at any time by contacting us using the contact details provided under the "Contact Us" section below;
- Object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information;
- Withdraw your consent at any time if we have collected and process your Personal Information with your consent;
- Complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including US and Canada) are available here : https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm)
To exercise any of these rights please contact us in accordance with the contact details set forth below in Section 14 below. Please note that if you are not subject to EU law, these rights do not apply to you.
7. DATA SECURITY AND RETENTION
We take reasonable measures to protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Although Company uses reasonable efforts to help protect your information, transmission via the Internet is not completely secure and Company cannot guarantee the security of your information collected through our Services. Except as otherwise set forth under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. We retain the information collected via our Services until such time as you choose to close your account. After that time, we may aggregate the data and retain it for analytical purposes. We may also retain your information on backup media to comply with applicable law, to support financial audits, to resolve disputes, to maintain compliance efforts, and for other legitimate business reasons.
8. PROMOTIONAL COMMUNICATIONS
By signing up for an account, you may receive periodic emails from Company. If you consented to receiving promotional email communications, you can opt out of receiving such communications from us at any time by (i) following the instructions provided in those communications; (ii) modifying your Email Preferences in the Account Settings of your account; or (iii) contacting us through the Services. Please note that even if you opt out of receiving promotional communications, we may continue to send you non-promotional emails and other types of communications, as permitted by law, such as service emails relating to our ongoing business relationship. Service emails contain service-related announcements that affect your account, such as product order confirmations, reward or payment updates, and responses to your comments and feedback submitted to us. Company mobile applications, browser extensions, and websites may send you notifications, such as alerts, sounds, and icon badges. Push notifications or in-app messages may include both operational messages and promotional messages regarding products, services, and offers that may be of interest to you. When using mobile applications, push notifications and other mobile alerts can be configured in the settings of your mobile device. As with emails, even if you opt out of receiving promotional communications, we may continue to send you non-promotional push notifications, such as those about your use of the applications or our ongoing business relations.
9. ANALYTICS, TARGETING, TRACKING
10. THIRD-PARTY DATA
11. SOCIAL FEATURES
12. SOCIAL LOGINS
Our Services or Apps offer you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.
13. REFERRAL PROGRAMS
Company may offer features which allow you to inform an individual about our Services. If you choose to use our referral features, we will ask you for your referral’s email address to send them an electronic communication inviting them to join our Services. Company will store this information for the sole purpose of sending this email and tracking the success of our referral program. If you choose to participate in our referral programs, you represent and warrant that you have a personal relationship with your referral and that you are authorized to share their information with Company for the purpose of sending this communication to invite them to join the Services. If you believe that one of your contacts has provided us with your Personal Information and you would like to request that it be removed from our database, please contact us at firstname.lastname@example.org.
15. CONTACT US