Updated: February 2, 2023
Protecting your privacy is important to Perfect365, Inc. (“Perfect365,” “us,” “our,” or “we”). This Privacy Policy contains important information on how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
Please read this Privacy Policy before using the Perfect365 family of mobile and internet-based products and services, including but not limited to perfect365.com and the mobile applications, Perfect365, Perfect365 Video, and Perfect365 Studio, and all publicly-available websites and subdomains provided by us on which a link to this Policy is displayed (collectively or individually referred to as the “Application”). BY USING ANY APPLICATION, YOU CONSENT TO THE COLLECTION, TRANSFER, PROCESS, STORAGE, DISCLOSURE, AND USE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS, PLEASE DO NOT USE AN APPLICATION.
This Privacy Policy is part of the Terms of Service for the Application and includes any separate privacy notices and/or notices posted on particular pages of the Application that may provide more detail regarding the information we collect on those pages, why we need that information, and choices you may have about the ways we use that information. No matter where your information is collected, used, transferred or stored, if it was collected through the Application, it will be subject to the terms of this Privacy Policy.
We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
Information you provide us directly
Information We Collect from Your Use of the Application
Certain location, device, and usage information may be collected when the Application is in use or runs in the background on your device. If you do not want this information to be linked to your device, you may go to your device “Settings” (which are somewhat different for iOS and Android devices) and opt out of interest-based or personalized advertising.
In addition to some of the specific uses of information we describe in this Privacy Policy, we may use information that we receive and the choices you make in your settings:
Perfect365 treats your personal information with care. We only pass personal information to our affiliates and third parties to the extent described here and within the scope of the purpose limitation under applicable data protection law.
Third-Party Service Providers
We use a variety of third-party service providers to help us provide the Application, including business analytics, marketing, payment processing, IT, and virtual currency providers. These providers have limited access to your information to perform these tasks on our behalf and are contractually obligated to use it consistent with this Privacy Policy.
Third-Party Advertisers, Advertising Network, Agencies, Marketers, Cybersecurity Partners
We may share or disclose non-personally identifiable information, aggregated, usage information, geolocation Information or device-level information (such as anonymous usage data, platform types, number of clicks, location data etc.) with unaffiliated partners and third parties (e.g. advertisers, advertising networks and platforms, agencies, other marketers, retailers, cybersecurity partners) that wish to market products or services to you or for cybersecurity purposes. You can control or disable the use of location services for the Application in the device’s settings menu. See Section 6 “Your Choices about your information” of this Privacy Policy for further instructions. Additional terms from select partners can be found here.
Other Users
Any information that you provide to other users, including beauty professionals, via the Application are shared and disclosed to such other users. By sending your information to other users, you acknowledge and agree that they may contact you via the Application.
Business Transfers and Affiliates
We may share your information with companies or organizations connected or affiliated with Perfect365. We may also transfer your information to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Perfect365’s business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.
Legal Disclosures
Notwithstanding anything to the contrary in this Privacy Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or our users’ rights or property. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.
During the last year, Perfect365 has sold personal information it has collected to our business partners (i.e., “third parties” under CCPA), for their business and commercial purposes. More specifically, Perfect365 has shared personal information with our business partners for the purpose of enabling and improving their marketing and advertising campaigns, from identifying potentially interested consumers to measuring the effectiveness of the marketing and advertising campaign, including marketing and user and data analytics. We have additionally shared personal information for disease prevention and cybersecurity purposes. Perfect365 does not sell personal information to individual consumers.
During the last year, Perfect365 has disclosed personal information to service providers and contractors (e.g., cloud computing and storage vendors; security contractors, and consultants), for Perfect365’s own operational business purposes.
Perfect365 does not sell personal information about consumers younger than 18 for any purpose.
Perfect365 does not engage in profiling in furtherance of “decisions that produce legal or similarly significant effects.”
While we have sold or disclosed for a business purpose the above information in the last 12 months, you have the right under the CCPA and certain other privacy and data protection laws, as applicable, to opt-out of the sale of your personal information. If you exercise your right to opt-out of the sale of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link.
Account Information
You may update or correct information you have provided to us by going into the settings screen (or “Me”) within the Application. If you wish to deactivate your account, please delete the Application, but note that we may retain your information as required by law and for business purposes. Refer below for additional information on your right to deletion and our deletion practices.
Promotional Communications
You may opt out of receiving promotional communications from us by following the instructions in those messages. If you opt out, please note that we may still send you Application-related communications, such as those about your account or our ongoing business relations, like notifications about updates to this Privacy Policy.
Interest-Based Advertising Services
You may opt-out from any interest-based advertising by turning on “Limit Ad Tracking” in your device settings.
To limit Ad Track on an Apple device, see instructions at: https://support.apple.com/en-us/HT202074.
Apple has recently added a feature where upon download of the application a popup stating “Allow Cross App Tracking” will appear that will allow the user to select their preferences for tracking and targeted advertising. The user can also go into their settings and disable or enable both tracking and location services for all applications.
To limit Ad Tracking on an Android device, see instructions at: https://support.google.com/ads/answer/2662922. Android has an option in Settings to “Opt Out of Personalized Ads.”
When you have opted out using this setting on a device, advertisers will not use in-app information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests. Please note, however, that opting-out will not block general advertisements that are sent at random, and not tied to the perceived interest of the user of a particular device.
Users may learn more about personalized and behavioral advertising and how to opt out of this type of advertising from the Digital Advertising Alliance at www.aboutads.info and Networking Advertising Initiative at www.networkadvertising.org/choices/.
Control or Disable the Collection of Geolocation Information
We do not collect geolocation information from you unless we obtain your explicit consent through the device’s settings (e.g., “Location Services”). You can also control the collection of certain precise location information by changing the preferences on your mobile device (certain services may lose functionality as a result).
Push Notifications
We may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings within the Application or your device settings.
Third Party Use of Cookies and Other Tracking Technologies
Some content or applications related to the Application are served by third-parties, including advertisers, ad networks and servers, content providers, service providers, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use the Application. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
We will not retain your personal information for longer than is allowed under the applicable data protection laws and regulations or for longer than is justified for the purposes for which it was originally collected. We will delete the personal information when we no longer need it for the purposes for which it was collected, unless Perfect365 is required by law to keep data for a certain period of time.
We do not knowingly collect or solicit any information from anyone under the age of 16 or knowingly allow such persons to register for the Application. The Application and its content are not directed at children under the age of 16. In the event that we learn that we have collected personal information from a child under age 16 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 16, please contact us at [email protected].
Perfect365 may transmit your information to its services, data centers, or service providers outside of the United States for storage and/or processing. As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements.
By registering for and using the Application, you consent to the transfer of information to any country in which Perfect365, its affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.
We use commercially reasonable safeguards to help keep the information collected through the Application secure. However, Perfect365 cannot ensure the security of any information you transmit to the Application or guarantee that information on the Application may not be accessed, disclosed, altered, or destroyed. You are responsible for maintaining the secrecy of your unique password and account information at all times. Your privacy settings may also be affected by changes the social media services you connect to Perfect365 make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.
Perfect365 has implemented appropriate technical and organizational measures to ensure an appropriate security level for the risk involved. The risk analysis takes into account the risk of infringing against the rights of individuals concerned, the costs for implementation, as well as the type, extent, context and purposes of the data processing.
These measures include:
The Application may contain links to third party sites or online services. We are not responsible for the practices of such third parties, whose information practices are subject to their own policies and procedures, not to this Privacy Policy.
As described above, Perfect365 collects various categories of personal information when you use the Application, including identifiers, commercial information, internet or other electronic network or device activity information, geolocation data, and professional information. A detailed description of the categories of personal information we collect and how we use such personal information is provided above in Section 2 (Information We Collect) and Section 3 (How We Use Your Information). Section 4 (Information Sharing and Disclosure to Third Parties) and Section 5 (Personal Information We Sold or Disclosed for a Business Purpose) describe the categories of third parties with whom we share personal information for a business purpose.
In the context of processing personal information of U.S. residents, certain states provide their residents with additional rights under consumer privacy laws if such laws are applicable to the data collector/processor. The following is a summary of some (but not all) of the rights you may have under various state laws.
California
If you are a California resident, you have the following rights (free of charge) under the California Consumer Privacy Act and the California Privacy Rights Act with respect to your Personal Information:
| Disclosure of Personal Information We Collect About You |
You have the right to request we disclose to you free of charge the following information covering the 12 months preceding your request: · The categories of personal information we have collected about you; · The categories of sources from which the personal information is collected; · Our business or commercial purpose for collecting or selling personal information; · The categories of third parties with whom we share personal information, if any; and · The specific pieces of personal information we have collected about you. Please note that we are not required to: retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or provide the personal information to you more than twice in a 12-month period. To submit a request for information, please email us at [email protected]. |
| Personal Information Sold or Used for a Business Purpose |
In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: · The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and · The categories of personal information that we disclosed about you for a business purpose. You have the right under the CCPA and certain other privacy and data protection laws, as applicable, to opt-out of the sale of your personal information. If you exercise your right to opt-out of the sale of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link. |
| Right to Deletion |
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: · Delete your personal information from our records; and · Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: · Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; · Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; · Debug to identify and repair errors that impair existing intended functionality; · Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; · Comply with the California Electronic Communications Privacy Act; · Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; · Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; · Comply with an existing legal obligation; or · Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information. |
| The right to request the business limit the use and disclosure of sensitive personal information |
You have the right under the CPRA to request that we limit the use of your sensitive personal information to only that which is necessary for providing products or services to consumers. Under the CPRA, the “Sensitive Data” categories include: ● Social Security numbers (SSNs), ● Driver’s license ● Financial account or card numbers ● Precise geolocation ● Racial and ethnic characteristics ● Religious and philosophical beliefs ● Union membership ● Contents of mail, email, and text messages ● Genetic and biometric data |
|
Protection Against Discrimination |
You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: · Deny goods or services to you; · Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; · Provide a different level or quality of goods or services to you; or · Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information. |
We will work to process all verified requests within 45 days. If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay.
To exercise any of these rights, please email [email protected]. We will not discriminate against you for exercising any of your privacy rights.
Colorado
Colorado residents have rights under Colorado’s Consumer Privacy Act (“CPA”) regarding the collection, use, and sharing of their personal data. Perfect365 may engage in “targeted advertising” as that term is defined in the CPA. You have the right to opt-out of targeted advertising as described in Section 6 (“YOUR CHOICES ABOUT YOUR INFORMATION”). You may also contact us at [email protected] to exercise any of your rights. We will not discriminate against you for exercising any of your privacy rights.
If you are a resident of Colorado, you also have the following rights:
To exercise any of these rights, please email [email protected]. We will not discriminate against you for exercising any of your privacy rights.
Connecticut
Under the Connecticut Data Privacy Act (“CTDPA”), Connecticut residents may have certain rights around the collection, use, and sharing of their personal data. Perfect365 may engage in “targeted advertising” as that term is defined in the CPA. You have the right to opt-out of targeted advertising as described in Section 6 (“YOUR CHOICES ABOUT YOUR INFORMATION”). You may also contact us at [email protected] to exercise any of your rights. We will not discriminate against you for exercising any of your privacy rights.
Nevada
Nevada’s internet privacy law (SB 220) requires website operators to provide a way for Nevada consumers to opt-out of the sale of certain information that the website operator may collect about them. If you wish to opt-out of any sale of covered information collected about you, you are able to make this request by emailing [email protected] or by visiting our homepage and clicking on the Do Not Sell My Personal Information link.
Virginia
Under the Virginia Consumer Data Protection Act (“VCDPA”), Virginia residents may have certain rights around the collection, use, and sharing of their personal data. Perfect365 may engage in “targeted advertising” as that term is defined in the CPA. You have the right to opt-out of targeted advertising as described in Section 6 (“YOUR CHOICES ABOUT YOUR INFORMATION”). You may also contact us at [email protected] to exercise any of your rights. We will not discriminate against you for exercising any of your privacy rights.
Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not currently respond to DNT signals.
Perfect365 may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of Perfect365 or the Application after any modification to this Privacy Policy will constitute your acceptance of such modification.
If you have questions or concerns about Perfect365’s Privacy Policy or to submit a request for information, please contact us at [email protected].
Last modified: December 31, 2022
Perfect365 (“Perfect365” or the “Company”) is collecting your personal information to support our business operations, as set forth in this Notice and our Privacy Policy (above). Any capitalized terms not defined in this Notice have the meanings given to them in the Privacy Policy.
We may collect the personal information categories listed in the table below:
Category Examples:
We use information that we collect about you or that you provide to us, including any personal information:
In the preceding 12 months, we have sold to or shared with one or more third parties the following categories of personal information for a business purpose as outlined in Section 5 of the Privacy Policy. However, you have the right under the CCPA and certain other privacy and data protection laws, as applicable, to opt-out of the sale of your personal information. If you exercise your right to opt-out of the sale of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link.
We retain personal information only as needed to achieve the purposes for which the information was collected. In certain cases, we may need to retain personal information for purposes required under applicable law, for tax or audit purposes, or for other lawful purposes.
If you have any questions or comments about this notice, the ways in which Perfect365 collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under applicable privacy law, please do not hesitate to contact us at:
Perfect365
101 Jefferson Drive
Menlo Park, CA 94025
[email protected]