This Privacy Policy applies to your access and use of the Anastasia Beverly Hills, LLC (“we”, “us” or “our”)
Virtual Try-On mobile app, and any features or tools therein that link to this Privacy Policy (the “Service”).
The Privacy Policy describes how we process your personal information in conjunction with your use of the
Service. By accessing or using the Service, you acknowledge that you have read and understand the terms of this
Privacy Policy. We will notify you of changes to this Privacy Policy by posting the amended terms on the Service
and providing any advance notice required by law. If you do not agree to the new terms, you should stop using
the Service. Otherwise, the new terms will take effect on the date listed in the notice we provide.
1. Information We Collect
When you use our Service, we collect information that identifies you or relates to you as an individual (“personal
information”) including:
a) Phone Numbers: We collect your phone number when you send a text message to get access to the Service.
b) Photographs: When you upload your photo we collect and store your photo only to provide our Services. Without
your photo we cannot provide you with the Service. We do not use your photo to uniquely identify you or distinguish
you from other users. We do not use your photo for marketing, advertising or any data-mining purposes.
TrueDepth API is used in the application for analyzing the user's face in order to be able to provide eyebrow
recommendations. The provided recommendations consider Anastasia Beverly Hills’s patented Golden Ratio and the data
from TrueDepth API is used to calculate what eyebrow type would be appropriate for that particular user. The data
collected by the TrueDepth API is never stored remotely, given to third parties, or used for any purposes other than
providing the Services. The face data only remains on your device, and never leaves your device at any time.
c) Information You Voluntarily Provide: We collect your email address and survey answers, but only to the extent you
choose to provide us with that information.
2. How We Use Your Information
a) Provide the Service: Once you upload the photo the Service, we will provide you with the suggestion for the best
eyebrow shade color.
b) Research and Development: We use your photo to improve the algorithm of the application. With each additional
picture input, our ability to correctly match shades gets better and better. We may further utilize your personal
information to improve our online services, analyze usage and interests, identify usage trends, determine the
effectiveness of our content and offerings, and to operate and expand our business activities.
c) Marketing: We may send you follow-up text messages with information about our products or promotions. If we do
we’ll make sure to ask for your permission, or give you the option to opt out.
d) Enforce Our Agreements and Prevent Misuse: To maintain a safe, secure, and trusted environment for you when you
use the Service, we use your personal information to make sure our policies, and agreements with you and any third
parties are enforced. We actively monitor, investigate, prevent, mitigate, and report fraud, misrepresentations,
security breaches or incidents, other potentially prohibited or illegal activities on our Service for your
protection.
3. Sharing Information
We do not share your personal information except with third parties as described in this section.
a) Service Providers: We may disclose your personal information to third-party service providers to provide us with
services such as website hosting, and professional services such as information technology services and related
infrastructure. We have contracts in place with our service providers to ensure your information is adequately
protected and limited in use.
b) Corporate Transactions or Events: We may disclose your information to a third party in connection with a
corporate reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any
portion of our business, assets or stock, including in connection with any bankruptcy or similar proceedings.
c) Compliance with Law: We may use or disclose your personal information as we deem necessary or appropriate: (1)
under applicable law, including laws outside your country of residence; (2) to respond to requests from public and
government authorities including public and government authorities outside your country of residence; (3) to comply
with subpoenas and other legal processes; (4) to pursue available remedies or limit damages we may sustain; (5) to
protect our operations or those of any of our affiliated companies; (6) to protect the rights, privacy, safety or
property of us or others; and (7) to enforce our terms and conditions.
4. Security
We are committed to securing your personal information. We have put in place commercially reasonable physical,
electronic, contractual and managerial procedures. However, no system is perfect or can guarantee that unauthorized
access or theft might not occur.
5. Notice to California Residents
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018, we
collect the following “personal information” categories: identifiers (your phone number and photo), and internet or
similar network activity. The sections above explain the reason why and how we collect information, and with who we
share the information. Under the CCPA you have the following rights, subject to certain exceptions: (a) the right to
request we delete your personal information; (b) the right know the types of information collected, how we use it
and who we share it with in the preceding 12 months; (c) the right to opt-out of any sale of your personal
information; and (d) the right not to be discriminated against for exercising any these rights. We do not sell any
of your personal information. To exercise your rights to know and/or to delete, you will need to submit a verifiable
consumer request by: emailing us at
info@anastasiabeverlyhills.com, or calling us at
1-800-310-3773. You may also have an authorized agent, a person registered with
the California Secretary of State that you authorize to act on your behalf, to make a verifiable consumer request on
your behalf.
You are entitled to request and receive once a year, free of charge, a notice from us describing what categories of
personal customer information (if any) we shared with third parties or corporate affiliates for their direct
marketing purposes during the preceding calendar year. Your written request should be submitted to the address
listed in Section 9.
Some Internet browsers include the ability to transmit Do Not Track signals (“DNT”). Since uniform standards for DNT
have not been adopted, our Service does not process or respond to DNT signals.
6. Notice to Individuals in Europe
This section only applies to individuals using or accessing our Service while located in the European Economic Area
the United Kingdom, or Switzerland (collectively, “Europe”) at the time of data collection. If any terms in this
section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in
Europe. We are a data controller with regard to any personal information collected from individuals using its
Service. We will only contact you if you are located in Europe by electronic means based on our legitimate
interests, as permitted by applicable law or with your consent. You can object to direct marketing at any time by
emailing us at
info@anastasiabeverlyhills.com.
Under the EU General Data Protection Regulation, we rely on your consent, fulfillment of the contract and/or our
legitimate interest to provide our Service, better understand you, to maintain and improve the accuracy of the
information we store about you, and to better promote or optimize our Service as the legal basis for our processing
described in Sections 2, 3(a) and 3(b), above. We rely on our legal obligations, the public interest, or in your
vital interests as the legal basis for processing described in Section 3(c).
Subject to certain exceptions and limitations, you have the following rights, which you can exercise by contacting
us at
info@anastasiabeverlyhills.com: the right to request to
access, correct, to port or delete your personal information, to object to processing or you can request that we
restrict processing of your personal information. If you consented to processing, you can withdraw your consent at
any time. If you believe we have infringed or violated your privacy rights, please contact us at
info@anastasiabeverlyhills.com so that we may resolve your
dispute directly. You have the right to complain to your local data protection authority about our collection ad use
of your personal information.
7. International Transfers
When you access our Service, your personal information may be processed in the United States or any other country in
which we, our affiliates, or service providers maintain facilities. The data protection laws in those countries may
be less protective than the laws in your jurisdiction. If you do not want your information transferred to,
processed, or maintained outside of the country where you are located, you should stop accessing the Service. If you
are accessing our Service while located in Europe, please note that the transfer of your personal information out of
Europe is necessary for the performance of our contract with you. To the extent we transfer personal information
collected from an individual located in Europe to another organization located in a country that the EU considers
not to provide an adequate level of data protection, we rely on legal transfer mechanisms such as Standard
Contractual Clauses or GDPR, Article 49 derogations in relation to such transfers.
8. Children
Our Service is not intended for or directed to children under 16. If we learn we have obtained any personal
information about a child under age 16, we will delete that information.
9. Contact
If you have any questions or concerns regarding this policy, please contact us at
info@anastasiabeverlyhills.com or by mail at Consumer
Relations, Anastasia Beverly Hills, LLC, 10635 Santa Monica Blvd, Ste 300 Los Angeles CA 90025.