Privacy Policy
PRIVACY POLICY
Last updated December 29, 2023
we
us
our
process
Services
Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns?
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our
table of contents
below to find the section you are looking for.
What personal information do we process?
personal information you disclose to us
.
Do we process any sensitive personal information?
Do we receive any information from third parties?
How do we process your information?
how we process your information
.
In what situations and with which parties do we share personal information?
when and with whom we share your personal information
.
How do we keep your information safe?
how we keep your information safe
.
What are your rights?
your privacy rights
.
How do you exercise your rights?
data subject access request
Want to learn more about what we do with any information we collect?
Review the privacy notice in full
.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. WHAT ARE YOUR PRIVACY RIGHTS?
8. CONTROLS FOR DO-NOT-TRACK FEATURES
9. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
10. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short:
We collect personal information that you voluntarily provide to us when you register on the Services,
express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You.
Sensitive Information.
Application Data.
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Personal information you disclose to us
GlowedUp may voluntarily collect images containing your face. These images are used to generate scan results through our proprietary face analysis technology, aimed at providing you with personalized feedback. We want to clarify that we do not extract or store any biometric identifiers or facial recognition data from these images.
The face data is solely for the purpose of enhancing your user experience by offering tailored recommendations based on the analysis of the submitted images. Storage and Sharing: The images and any associated face data are stored securely on your device only.
We assure you that this data is not shared with any third parties, and is solely used for the purpose of delivering the services you have requested within our app. Retention: We retain the submitted images and any generated data only as long as necessary to provide you with our services.
Typically, this duration does not exceed 15-20 mins. After this period, all data is permanently deleted from our servers, ensuring your privacy is safeguarded. We also delete all locally stored and user generated data upon the deletion of the app itself
In Short:We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
selfies
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
biometric data
Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Apple. You may find their privacy notice link(s) here: https://www.apple.com/legal/applepayments/privacy-notice/#:~:text=To%20protect%20your%20personal%20information,availability%20of%20your%20personal%20information..
Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s contacts, camera, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short:
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
The information we collect includes:
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short:
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
To facilitate account creation and authentication and otherwise manage user accounts.
To deliver and facilitate delivery of services to the user.
To save or protect an individual's vital interest.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short:
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
Consent.
withdrawing your consent
.
Performance of a Contract.
Legal Obligations.
Vital Interests.
If you are located in Canada, this section applies to you.
withdraw your consent
at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are met
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
For identifying injured, ill, or deceased persons and communicating with next of kin
If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
If the collection is solely for journalistic, artistic, or literary purposes
If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short:
We may need to share your personal information in the following situations:
Business Transfers.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short:
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short:
7. WHAT ARE YOUR PRIVACY RIGHTS?
In Short:
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or
UK data protection authority
.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent:
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
Opting out of marketing and promotional communications:
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at help@glowedup.app.
8. CONTROLS FOR DO-NOT-TRACK FEATURES
9. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short:
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
Category
Examples
Collected
A. Identifiers
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
B. Personal information as defined in the California Customer Records statute
Name, contact information, education, employment, employment history, and financial information
Gender and date of birth
Transaction information, purchase history, financial details, and payment information
Fingerprints and voiceprints
Device location
Images and audio, video or call recordings created in connection with our business activities
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us
Student records and directory information
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
We will use and retain the collected personal information as needed to provide the Services or for:
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
HOW DO WE PROCESS YOUR INFORMATION?
Will your information be shared with anyone else?
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
California Residents
CCPA Privacy Notice
This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
Your rights with respect to your personal data
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell or share personal information to third parties;
the categories of personal information that we sold, shared, or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
the business or commercial purpose for collecting, selling, or sharing personal information; and
the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
You may object to the processing of your personal information.
You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us by submitting a
data subject access request
,
or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
Colorado Residents
This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
To submit a request to exercise
these
rights described above, please email
or
submit a
data subject access request
.
Connecticut Residents
This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
data subject access request
Utah Residents
This section applies only to Utah residents. Under the Utah Consumer Privacy Act (UCPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data
data subject access request
Virginia Residents
Under the Virginia Consumer Data Protection Act (VCDPA):
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Exercise your rights provided under the Virginia VCDPA
data subject access request
Verification process
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Attorney General to submit a complaint
10. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short:
You may have additional rights based on the country you reside in.
Australia
and
New Zealand
If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:
offer you the products or services that you want
respond to or help with your requests
manage your account with us
confirm your identity and protect your account
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Office of the Australian Information Commissioner
Office of New Zealand Privacy Commissioner
Republic of South Africa
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:
The Information Regulator (South Africa)
General enquiries:
enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form 5):
PAIAComplaints@inforegulator.org.za
&
POPIAComplaints@inforegulator.org.za
11. DO WE MAKE UPDATES TO THIS NOTICE?
In Short:
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
contact us by post at:
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
data subject access request
.