This privacy policy describes how TrueBeauty Inc. (collectively, “TrueBeauty”, “we”, “us” or “our”) collect, use, share, and protect your personal information when you use our Services. It also tells you about the rights and choices you have with respect to your personal information, and how you can reach us to get answers to your questions. If you have any questions or comments about this Privacy Policy, please contact us at hello@truebeauty.ai.

This privacy policy applies to all use of our websites, www.truebeauty.ai, (hereinafter “Web”), and all use of our application for mobile devices (hereinafter “App”). The Web and the App together form our Service offers to you (hereinafter “Platform”).

The following are the categories and specific types of personal information that we collect:

• Basic Identifying Information: Including your full name, alias, e-mail address, date of birth, account name, username or social media handle, or other similar identifiers.
  
• Device Information and Other Unique Identifiers: Including device identifier, internet protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifier, or similar unique identifiers.
  
• Internet or Other Network Activity: Including browsing or search history, and information regarding your interactions with our websites, mobile applications, emails, or advertisements.
• Geolocation Data: Including information that permits us to determine your location, such as if you manually provide location information or enable your mobile device to send us precise location information.
• Physical Characteristics: Including skin tone and type, hair color and type, eye color, and other beauty profile information you provide.Audio and Visual Information: Including photographs, images.
• Inferences: Inferences drawn from or created based on any of the information identified above.

We collect personal information about you:

• When you register for an account and create a profile.
• When you submit products, products ratings and reviews.
• Using cookies and other automatic data collection technologies.

A cookie is a small text file stored on your computer, tablet, mobile or similar, for the purpose of recognizing your device if you visit our website again (such as login, language, font size and other settings). This makes it possible to customize the Website to your browser. A cookie may contain text, numbers or e.g. a date, but generally there are no personal data in a cookie. It is not a program and thus cannot contain a virus.

When you visit our website, we collect information about you that allows us to identify your device. The information is used to customize and improve our content on the website and to get statistical information (not personal information), so we can provide you with the best possible experience. If you choose not to accept cookies at all you may not be able to use all the functions of our website.

You can modify your browser, so cookies are not stored on your computer, tablet, mobile etc. Be aware, however, that without cookies, you may not be able to use all the functions of our website.

Besides our own cookies, we use cookies from third parties, e.g. from suppliers of advertisements and analytic tools and from suppliers of social media. These third-party cookies are used for marketing purposes and for improving the functionality of the website. We use the following third party cookies: Google, Facebook.

Our Services are made to be simple and easy to use, but a lot of work goes into keeping them up and running! We process your personal data to provide you with an amazing set of products and services that we improve relentlessly.  Here are the ways we do that:

• We process your personal data to provide you with access to our Platform.
• We process your personal data to deliver and improve the Platform, and manage our business, to improve our offerings, develop new features and updates, develop personalization services and other types of service, including but not limited to develop and implement algorithms and machine learning. This processing is on the basis of our legitimate interest to improve our platform and services.
• We also use your personal data to inform you about new features and updates on the Platform, and let you know about our policies and Terms and Conditions. The processing of personal data is performed based on your freely given consent to receive marketing by e-mail and push notifications provided when signing up to the Platform, which you may withdraw at any time by clicking the “Unsubscribe” button in any marketing e-mail.

TrueBeauty does not share your personally identifiable information with third parties. TrueBeauty may use this data to maintain the quality of our Services, notify you about changes, allow you to participate in interactive features of our Service, provide customer support, to detect and prevent technical issues. We may share personal data regarding you if we are obligated to do so by law.

Personal information is maintained on our servers or those of our service providers, and is accessible by authorized employees, representatives, and agents as necessary for the purposes described in this privacy policy. We realize that individuals trust us to protect their personal information. We maintain reasonable and appropriate physical, electronic and procedural safeguards designed to help protect your personal information. While we attempt to protect your personal information in our possession, no method of transmission over the internet, or security system is perfect, and we cannot promise that information about you will remain secure in all circumstances.

As provided by the General Data Protection Regulation, you have the right to:

• Access personal data regarding you. You can always access your account to review the personal data we have collected about you. You may delete and amend the data collected. You also have the right to obtain a copy of the personal data free of charge. However, we may charge a fee corresponding to administrative costs if further copies of the information are requested, or if the request is unfounded or excessive.
• Ask for rectification of incorrect or inaccurate data concerning you, or to have incomplete personal data completed. You can use your access to your account to update your personal data.
• Ask for erasure of personal data regarding you (under certain circumstances).
• Ask for the restriction of the processing of your data (under certain circumstances).
• Object to the processing of your data for marketing purposes by withdrawing your personal consent.
• You can at any time withdraw your consent by deleting your profile or delete your account contacting us.

When we receive a request to access, rectify, erase or port data, we may ask you for additional information in order to confirm your identity and ensure data security.

We store your personal data for as long as your account is active. We may also store some of your personal data to comply with our legal obligations. You may add or update certain information to your account. When you update information, however, we often maintain a copy of the unrevised information in systems back-ups for a period of time until our backup is updated with the latest version. You may request deactivation of your account by following the instructions at the Platform. If you deactivate your account, we do not delete your information but holds it for you until such time as you either activates your account again or delete it. When you delete your account, we delete the data attached to your account including your username. The username will be deleted from all reviews, and the reviews will be anonymized for future viewing. Please note that some information may remain in our records after your account has been deleted, and that we may only be able to delete this information later when updating our backups.

Our Platform is not intended for or directed to children under the age of 13. We do not knowingly collect personal information directly from children under the age of 13 without parental consent. If we become aware that a child under the age of 13 has provided us with personal information, we will delete the information from our records.

TrueBeauty does not disclose the personal information we collect about you to third-parties for their direct marketing purposes. However, should we ever share for this purpose, California’s Shine the Light law permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information we disclosed to third-parties for direct marketing purposes in the last 12 months. If you are a California resident and would like a copy of this notice, please contact us at hello@truebeauty.ai Please note that not all information sharing is covered by Shine the Light requirements and only information on covered sharing will be included in our response.

Some browsers offer a “do not track” (“DNT”) option. Because no common industry or legal standard for DNT has been adopted by industry groups, technology companies, or regulators, we do not respond to DNT signals. We will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

TrueBeauty may use suppliers located outside the EU/EEA to process data on behalf of TrueBeauty according to standard data protection clauses adopted by the European Commission and to TrueBeauty’s performance of the contract with you. By submitting your personal information to us you agree to the transfer, storage, and processing of your personal information in a country other than your country of residence including, but not necessarily limited to, the United States.

We may change this Privacy Policy from time to time. But when we do, we’ll let you know one way or another. Sometimes, we’ll let you know by revising the date at the top of the Privacy Policy that’s available on our website. Other times, we may provide you with additional notice (such as adding a statement to our websites’ home pages or providing you with an in-app notification).

This Privacy Policy is effective as of May 16, 2022