Privacy Notice – Beetles UK

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December 13, 2023

Privacy Notice

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Privacy Notice

Summary Privacy Notice & Notice at Collection
 
When we say “Us”, “Our”, or “We”, We are referring to GELAB COSMETICS.LLC.  This Summary Privacy Notice supplements Our Privacy Notice by providing key information to You about how We collect and use personal information about You.   
Our detailed Privacy Notice describes the types of personal information We collect from You directly, from Your interactions with Us (on Our websites, mobile apps, and digital tools (collectively, “Sites”) and advertising), and from third parties; how We use it; how We protect it; and Your rights as Our consumer.  Visitors from other countries should visit the Beetles gel polish brand site for Your part of the world. Our contact details are available at the end of the detailed Privacy Notice in the “How to Contact Us” section.  
What Types of Personal Information Do We Collect and for What Purposes? 
The personal information that We collect about a specific person will depend on, for example, Our relationship or interaction with that person. We collect personal information that You provide to Us, from Your engagement with Our brand Sites and platforms, advertising, media; from third parties who have Your permission to share it with Us; and automatically collected (such as through cookies and other similar technologies).  
We collect the following categories of personal information:  
Categories of Personal Information
Examples
Identifiers
Name
Postal Address
Telephone number
Mobile number
Online identifiers (e.g., Cookie IDs/MAC address)
Internet Protocol address
E-mail address
Account name/username
Social handle or moniker 
Device identifiers
Internet or similar network activity
Browsing history
Account login information 
Search history
Information on Your interaction with a website, application, or advertisement and related information  
Smart device and sensor data
Payment Information
Credit or debit card information
Information to process payments and prevent fraud
Legally Protected Characteristics
Characteristics of protected classes or groups under domestic law.  For example:  
Age (40 and over) 
Race, ethnicity, national origin
Sex, gender identity, gender expression
Marital status
Purchasing Information
Products or services purchased, obtained, or considered
Other purchasing or consuming histories or tendencies (e.g., beauty routines, beauty concerns) 
Loyalty activity and redemption
Account information 
Customer service records 
Health and safety-related information 
User-generated content (e.g, product testimonials, ratings and reviews, etc.)
Geolocation Data
Geolocation data includes information such as the following:  
General location information indicating the general physical location of you or your device (e.g., IP address or zip code) 
Precise information about your location if you allow us (or a third party who provides it to us) to collect it
Audio Visual Information
Photographs that you upload or share with us
CCTV video recorded at our facilities 
Call center recordings
Video images
Professional or employment-related personal information 
Career/profession
Professional credentials (e.g., professional license)
Other Information Considered Personal Information*
 
 *Some information in this category is addressed in other categories as well.
Name
Contact details such as telephone number and address
Age
Signature (including electronic signature)
Physical characteristics or descriptions
Payment information
Address
Education
Employment
Inferences drawn from any of these personal information categories
Inferences based on personal information about an individual to create a summary about, for example:  
beauty and related preferences,
characteristics,
behaviors on and off Site,
purchase patterns,
demographics,
household information. 
We collect and use this information to: 
Fulfil Your requests for products or services, manage Your orders, and process payments  
Administer and manage Your account or loyalty program membership 
To send You marketing communications, which may be tailored to Your ‘profile’ based on what personal information we know about You and Your preferences  
To provide tailored and personalized content, services, advertisements and offers, including based on Your beauty characteristics and preferences 
Post Your content and reviews on the Sites, our social media pages, and related-third party sites that retail or feature Our brands and products 
Manage any competitions, promotions, surveys, sweepstakes, giveaways, or contests You choose to enter
To manage, improve, and develop Our business,
Verify Your identity and detect and prevent fraud, and to maintain the security of Our products, Sites, and systems
To communicate with You, answer questions and otherwise interact with You, and create better experiences
Provide You with requested services or to complete transactions You request
To collect, evaluate, and monitor reports of undesirable events during or after use of Our products
Support Our everyday operations, including to meet risk, legal, and compliance requirements 
To enforce Our terms, and to protect Our rights, property, and safety, or the rights, property, and safety of others
For corporate governance, including mergers, acquisitions, and divestitures, and to otherwise comply with applicable laws
We combine information that We collect via one method (e.g., from a website or Our digital advertising) with another method (e.g., an offline event). For example, if You have an account with Us and are logged in, or otherwise provide personal information like an email, We associate information We observe about You with other information You or a third party provide to Us. We do this to get a more complete view of Your preferences for Our beauty products and services, which, in turn, allows Us to serve You better and with more customization and better beauty products. A more detailed description of the information We collect and how We use this information is available in the “How We Collect and Use Personal Information” section of the detailed Privacy Notice. 
When Do We Share Personal Information? 
We share personal information with third parties (vendors, agencies, and businesses) that help Us run Our Sites, Our business, and retail Our products to further Beetles’ beauty mission.  We may disclose information to Our service providers, to complete a transaction requested by You, when required by law or authorities, and in the event of a sale or reorganization of Our company.  More information is available about how we share personal information about You in the “How We Share Personal Information” section of Our detailed Privacy Notice.  
We do not ‘sell’ (as ‘sell’ is traditionally defined) personal information about Our consumers.  We do not make available or provide consumer’s names, phone numbers, addresses, email addresses, or other personal information to third parties in exchange for money.  Like many companies, however, We do share or make available personal information We collect with third parties to provide You with personalized advertising from Us and analytics.  For example, we share personal information with third parties such as social media platforms to optimize our marketing campaigns, display ads for Us, and measure the effectiveness of those ads on such platforms.  These companies use personal information to improve their own products and optimize their own ad targeting systems.  In some jurisdictions, this type of activity is considered (1) a ‘sale’, (2) a ‘share’ or ‘use’ of personal information for targeted advertising, or both, and subject to a right of opt-out.   
To exercise the right of opt-out where available in your jurisdiction please use one or more of the following:  
visit the “Your Privacy Choices” link on the footer of Our Site to submit a request regarding offline (non-browsing) personal information.  
click on “Cookie Settings” link on the footer of Our Site and change the setting regarding online (browsing) personal information.  
enable a browser-based opt-out signal such as the Global Privacy Control.  Where required by applicable law We will treat browser-based opt-out signals as requests to opt-out of the sale/sharing (or use) of personal information for targeted advertising for Your browser. If you are logged-in to Your account (where available), We will associate the browser-based opt-out signal with Your account and apply it to offline personal information.
How Long Do We Retain Personal Information? 
We will retain personal information about You for so long as Your account is active, you engage with Us, as needed to provide You services, and as necessary to comply with Our legal and/or regulatory obligations, to resolve disputes, to manage Our rights, and to enforce Our agreements. We do not control certain privacy settings and preferences maintained by Our social media partners like Facebook and Twitter. If You wish to make changes to those settings and preferences, You may do so by visiting the settings page of the appropriate social media site.
 

Detailed Privacy Notice

Table of Contents 
How We Collect Personal Information
What Personal Information We Collect & Use 
How We Share Personal Information 
How Long We Retain Personal Information
Your Privacy Choices
Privacy Rights Available under Domestic Laws
Children’s Information
Securing Personal Information About You
Third Party Links; Social Login
Cross-Border Transfers
Updates to this Privacy Policy
How to Contact Us
How We Collect Personal Information
We obtain personal information from the following categories of sources.  We combine personal information that We collect from one method (e.g., from a website, digital advertising engagement) with another method (e.g., an offline event).  For example, if You have an account with Us and are logged in, or otherwise provide personal information like an email, We associate information We observe about You with other information You or a third party provide to Us.   We do this to get a more complete view of preferences for Our beauty products and services, which, in turn, allows Us to serve You better and with more customization and better beauty products.   
Personal Information You Provide
We (directly or by third parties on Our behalf) collect personal information You provide to Us directly when You Interact with Us.  For example: 
Account creation and management.   We collect personal information during the creation or management of an account with Us.  When You sign up for an account You will need to provide certain information about Yourself, such as name and email address.  You may provide other personal information.  You may also be able to register and log in to Our Sites or chat features using Your social media account, such as Facebook or Google. These platforms may ask Your permission to share certain information with Us (e.g. name, gender, profile picture) and all information is shared subject to their privacy policies.  You can control the information that We receive by changing Your privacy settings offered by the relevant social media platform.
Newsletter and marketing subscriptions.  We collect and use personal information when You subscribe to receive Our marketing communications. 
Purchase and order management.   We collect and use personal information when You purchase products or services from Us, whether on Our Sites, in one of Our retail locations, or otherwise.  This includes payment details to complete a purchase.  
On Our social media platforms.   We collect and use personal information You publicly post on social media platforms or when You mention Us on social media platforms.  
Promotions.  We collect personal information during Your participation in a competition, game, contest, promotional offer, sample request, or response to a survey.  
User Generated Content.   When You submit content (such as images or rating and reviews on one of Our Sites or You agree to allow Us to re-use content You posted on social media).  We may ask You to participate in a survey or general research.  If you chose to take part in these, You may provide personal information in connection with Your response. 
Use of Our Sites and Services.   When You provide personal information while using Our Sites, such as completing forms or using services on Our Sites.  For example, if You use a chat feature on Our Sites, We (and a third party provider of chat software who provides Us with services) collect personal information You share during the interaction, interactions with Our chat tool, and transcripts of the chat conversation. You may use other features of Our Sites that may ask You to grant permission to access the camera or other features of Your computer or mobile device.  For example, to enable augmented reality features We make available. 
If You use social sharing to send Your image to a friend or post it online or if You save it to Your profile.
Customer Service.  When You ask questions relating to Our brands, Our products and their Use, or Your purchases or account. 
Personal Information We Observe or Collect Automatically
We (directly or by third parties) collect personal information We observe about You on Our Sites.  For example, We (or third-party companies (e.g., Google)) collect personal information automatically when You use or visit Our Sites, install and use Our mobile apps, view Our advertisements, interact with Our emails or other communications, or use Our products and services.  This personal information is collected through a variety of technologies, such as cookies, Flash cookies, JavaScript tags, software development kits, application program interfaces, Web beacons, and other technologies described below.   Information collected via automated means include identifiers (e.g., IP address, device ID, cookie ID, mobile advertising identifier), geolocation, commercial information, and internet or network activity (e.g., clickstream data, such as browsing and search history, other interactions with Our Sites).  We combine personal information collected automatically with personal information We already have about You. 
Cookies and Other Technologies:  Our Sites, applications, email messages, and advertisements may use cookies and other technologies such as pixel tags and web beacons.  These will collect online activity data such as date and time You visit the Site, duration of access, browser or app version used, URLs You come from and go to, and how You used our Site or interacted with emails and other messages.  These technologies are used help Us to:
✔ remember Your information so You do not have to re-enter it, 
✔ track and understand how You use and interact with Our Sites,
✔ tailor the Sites and Our advertising around Your preferences, 
✔ manage and measure the usability of the Sites, 
✔ understand the effectiveness of Our content, 
✔ otherwise enhance the Sites and Our beauty offerings, and 
✔ protect the security and integrity of Our Sites.
Our emails include pixels in Our messages to determine whether You open and interact with them.  Our Sites also use cookies and other technologies to help keep track of items You put into Your shopping cart including when You have abandoned Your cart and this information is used to determine when to send cart reminders (including messages via SMS). <
Mobile Services/Apps and Devices: We (directly or by third parties on Our behalf) use technologies that collect information from Your phone when You use Our mobile apps or Our ‘smart’ devices in Your home.  This information could include Your mobile phone or other device identifiers (including a mobile phone identifier (iOS IDFA and Android Advertising ID), Bluetooth ID, or other device identifier), information about Your phone or other device’s operating system, how You use the app or device, and Your physical location.  Certain of Our mobile apps and tools offer opt–in, geo–location services and push notifications.  
✔ Geo-location services provide location–based content and services, such as promotional offers and other personalized content. 
✔ Push notifications can include discounts, reminders or details about local events or promotions.  Most mobile devices allow You to turn off location services or push notifications.
If You turn on location services, We (or a third party on Our behalf) may collect location information, including information about the Wi–fi routers closest to You and the cell IDs of the towers closest to You to provide location–based content and services.   Additionally, most mobile devices will allow You to disable sharing or reset some device identifiers. 
✔ We also record customer service calls for quality assurance, maintain transcripts of chats using our chat tools (provided by a third party), and logs of Your interactions with our automated phone system and our chat bots.
Personal Information Received from Third Parties: 
We receive personal information from third party sources to update or supplement personal information You provide or We collect automatically.  We combine this personal information with personal information We collect either automatically or directly from You.   
Affiliates.  We receive or have access to personal information from other companies and brands under common ownership with Us. Other Users or Individuals who use Our Services.  For example, We operate and manage refer-a-friend or similar programs, where We collect email addresses and other contact information about You if a person invites You or refers You.  
Service Providers.   Our service providers that perform services on our behalf collect personal information and share some or all of this personal information with us.  For example, if You provide Us with permission to store payment information in Your account, We will receive a tokenized version of the credit card back from Our payment processor, and Your credit card issuer may provide Us with updated Payment Information in connection with the credit card issuer’s account update service.  
Social Media; Authentication Services.  You also can engage with Our brands, use chat or try-it-on features, applications, and log into Our Sites via social media platforms, such as Facebook (including Instagram) or Google.  If You link, connect, or login to one of Our Sites with a third-party service (e.g., Facebook, Google), We collect Personal Information You share with Us, or that the social media platforms share with Us.  When You engage with Our content on or through social media or other third-party platforms, plug-ins, integrations or applications, these platforms may ask Your permission to share certain information with Us (e.g. name, gender, profile picture, likes, interests, demographic information).  Such information is shared with Us subject to the third-party platform’s privacy policy.  You can control the information that We receive by changing Your privacy settings offered by the relevant social media platform. 
Transactions You Have Requested.   We receive personal information about you from third parties to complete a transaction you have requested.  For example, if You checkout with PayPal We will receive information back from PayPal to complete the transaction.
Other Sources.  We collect personal information from publicly available sources, third-party data providers, or through transactions such as mergers and acquisitions.  For example, We validate postal address information using third party services or third parties provide Us with additional information about You.  We combine that information with other personal information we maintain about You.  
These third-party sources include vendors that provide Us with services, advertising networks, data analytics providers, government entities, social media networks, companies that process payments, other Beetles affiliates, data brokers, companies that help Us detect fraud and safety issues, and companies who have received Your permission to share personal information with Beetles or when a third party needs to share personal information with Us to complete a transaction You have requested. This also includes information received from third parties about individuals who share common interests or attributes (e.g., color treated hair, individuals who purchased products similar to products We sell) to create user “segments,” which help Us to better understand and market to Our current or prospective customers.  
This information includes marketing and demographic data (including identifiers, commercial and purchasing information (i.e., products You have purchased or considered)), analytics information (including online information), internet or online information, demographics (e.g., including nationality, race, ethnicity), geolocation, and offline records, as well as inferences. 
We may also receive information from other companies that collect or aggregate information, including from publicly available databases.  This might include de-identified information about purchasing patterns, location of shoppers, and websites that are of interest to Our consumers. 
What Personal Information We Collect & Use
Examples of the categories of personal information we use, and why and how We use them, are outlined below.
 
 
Examples of Processing Activities
Examples of Personal Information Used
 
The actual personal information We use depends on Your factual circumstances and interactions with Us, but could include the following: 
 
Account Management:  We collect and use personal information to create, manage, and administer Your account or loyalty program membership.  You will need to provide basic identifiers and contact data to create an account.  You may need to provide a password (depending on whether You register using an email address or use a social login provided by Google or Facebook.  
You may provide other personal information in connection with Your account (such as preferences data, physical characteristics, health-related information, payment data (e.g., save a payment method to Your account), user generated content, or audio/visual data (e.g., add a picture to Your Account)).       
We associate other personal information We collect about You with Your profile to help Us understand Your interests and preferences.
Product Fulfilment:  If you purchase products or services from Us we will collect and use personal information about You  to: 
manage Your order(s), 
fulfil orders, and/or complete transactions You request, 
process Your payments, 
provide You receipts and order confirmations/updates,
track gift certificate values and/or redemptions;
and manage and process returns (which may require government identifiers) or disputes related to an order.  
On some products you may elect to participate in a recurring order or subscription program.     We (and a third party on Our behalf) will process personal information (e.g., product code, SKU, frequency, email address, next order date, saved payment information, shipping information) to process and manage Your recurring order or subscription.  A saved payment method on file with Us is required for recuring/subscription orders.
We use payment service processors to handle and process payments.  If you agree to save a credit card to Your account, we will receive back from Our third-party payment processors tokenized payment information. 
We will also collect and use personal information about You to complete other transactions You have requested, such as facilitating payment, shipping, and other rewards from Your selected third-party providers (e.g., process payments via PayPal or Apple Pay, or receive free shipping from ShopRunner if You are a ShopRunner member); to inform You when a product You wanted to purchase is available, or to process a donation You may make at the time of purchase.
Other Online or In-Store Services:  To provide You with the requested service or otherwise complete a transaction requested by You.  
For example, 
To allows You to virtually try-on Our products, 
To analyze Your personal and beauty characteristics so We can recommend the appropriate products and routines (including bespoke products and routines); 
To show You the nearest retail location that sells Our products, and 
To allow You to schedule appointments (and receive appointment reminders) for in-person or teleconsultations with beauty advisors or other 1:1 experiences.  
You may choose to provide physical characteristics and/or health and medical information in connection with some of these services.  If You use one of our virtual try on features or beauty tool(s), We collect, capture, possess, store, or obtain the picture You provide and data obtained or created from Your picture (including the automated recognition of various facial landmarks), that might qualify as biometric data or otherwise infer physical characteristics, skin concerns, or demographic data about You.
Many of these services will allow You to enter contact information (such as a name and email) so We can send You results (i.e., send You suggested routines or recommendations in response to Your use of a service).  We associate personal information collected during Your use of Our services (quiz responses, information You provide, beauty characteristics, recommendations, etc.) with Your beauty profile to help Us understand Your interests and preferences.
Site Functionality:  We collect and use personal information about You to enable Our Sites and services to function properly.  
For example to:
Ensure the proper display of content; 
Allow You to add items to or purchase items from Your cart, 
Allow You to log in (and keep You logged in), 
filling in or competing forms, 
Perform any customization or personalization attached to Your device or account (language, screen resolution, font preference, etc.), 
Perform troubleshooting, improve user experience and Our Sites (e.g., testing new ideas and layouts); and 
Provide features and functionality to Our Sites (e.g., web chat services, product recommendations, predictive sort, product search, and commenting and rating systems).     These services are provided by Us or by a third party on Our behalf.
Identifiers:
basic identifiers, such as first and last name, alias, account name, postal address, email address, signature, username, social media handle, or similar identifiers
government identifiers, such as driver’s license number or other government identifier
online identifiers, such as device identifiers; internet protocol address (IP address), cookies, beacons, pixel tags, mobile ad identifiers, or similar identifiers. 
Other Personal Information 
contact data, such as home address, shipping address, telephone number(s), mobile number(s), email address(es), etc. 
preferences data, such as subscription type (contact preference:  email, SMS; recurring order/subscription information), date created, date modified, and permission status.
payment or other financial data, such as credit or debit card number or other payment information.  
physical characteristics, such as personal descriptions, skin tone and type, hair color, eye color, and other beauty profile information You provide to Us or We collect.
health and medical data, such as information regarding skin conditions (e.g., acne, rosacea) in connection with a beauty service, online or in-store experience, or product recommendation. 
user generated content, such as any content (e.g., text, videos, images, ratings and reviews, etc.) You create and/or provide to Us (e.g., via Your “My Account” page, contacting Us, using the chat function on Our Sites, gift messages/other custom labels; or by participating in a contest, game, survey, etc).   
Commercial or Purchasing Information, such as products or services (e.g., gift certificate) purchased, obtained, or considered (e.g., order details, transaction information, products added to cart, shipping/return status); purchasing or consuming histories or tendencies; and loyalty activity and redemption (e.g., loyalty status, participation, points earned/redeemed, etc.). 
We may collect (in certain cases) public blockchain addresses, such as when you purchase an NFT from Us.  
Characteristics of Protected Classes 
demographic data, such as age, gender, race, ethnicity, household information, and birthday or age range, some of which may include protected classifications under domestic law.  
biometric data, such as information considered biometric information or a biometric identifier under domestic law. 
Internet or Other Network Activity 
technical data, such as browser information, bowser size, browser version, operating system and version, device information/type, language setting, smart device, sensor data, email client used; screen size/resolution, inferred geographic location by IP address; internet service provider, and network domain name.
browsing data, such as information related to Your use of Our Sites; where You came from, login details, location, data related to Your navigation of Our Sites (e.g., scroll, mouse movements), pages/ad/content You looked at, clicked, or tapped, creative shown, duration of Your visit, products You searched for and/or selected to create Your basket; and email messages opened and any links clicked-through.
Audio/Visual Information, such as photographs, images, videos, and recordings of Your voice (including when We record customer service calls).
Geolocation, such as information that allows us to determine Your location, such as if You provide Us with Your location information, We obtain estimates of geographic location (such as from IP address), or if You enable Your device to send us precise geolocation information. 
Inferences, using personal information about an individual to create a summary about, for example, an individual’s preferences and characteristics, including beauty and related preferences, characteristics, behaviors on and off site, purchase patterns, demographics, household information
To communicate with You.  We collect and use personal information to communicate with You about Your account, Our relationship, or to otherwise send You non-marketing communications.     For example, 
to send You notices of changes to a Beetles policy, 
to notify You if You win a prize promotion or other contest, and 
to send You a welcome email when You create an account, or other transaction or relationship-related communications, including to send notifications related to Your account, purchases, returns, exchanges, subscriptions, and reservations.
Customer Service and Support.  We also collect and use personal information to:
provide support, 
respond to questions, inquiries, or requests (e.g., process orders over the phone, update information on Your account, etc.), 
otherwise interact with You, and
to follow-up and perform corrective measures.  
If you contact Us via our chat feature, we (and our third-party service provider) will collect and maintain transcripts of Your communication with Us and Your interactions with Our chat tool.  If you call Us, we collect information about Your interaction with Our call system, as well as voice recordings and transcripts of Your conversations with Us.     This is used for: 
training & quality assurance, 
assessing customer satisfaction, 
perform and follow-up on corrective measures, 
improving Our Sites, stores, and customer service, and 
other purposes outlined in this Notice. 
This may include the collection and use of health and medical data, such as for cosmetovigilance purpose.  We collect, evaluate, and monitor reports of undesirable events during or after use of Our products, and to perform studies relating to the safe use of Our products.
Identifiers 
basic identifiers, such as first and last name, alias, account name, email, postal address, signature, username, social media handle (e.g., if you contact Us via social channels), or similar identifiers.
online identifiers, such as device identifiers; internet protocol address (IP address), cookies, beacons, pixel tags, mobile ad identifiers, or similar identifiers. 
Other Personal Information:
contact data, such as home address, shipping address, telephone number(s), mobile number(s), email address(es), etc. 
payment or other financial data, such as credit or debit card number or other payment information.  
physical characteristics, such as personal descriptions, skin tone and type, hair color, eye color, and other beauty profile information You provide or We collect.
health and medical data. 
user generated content, such as the content of Your communications with Us (including contents/transcripts of chat/calls, associated logs, contents of messages sent/received by Us, or social media posts or private messages) and/or any other content you create and/or provide or share with Us (i.e., survey responses and customer satisfaction scores).
Commercial or Purchasing Information, such as products or services (e.g., gift certificate) purchased, obtained, or considered (e.g., order details, transaction information, products added to cart, shipping/return status); purchasing or consuming histories or tendencies, and loyalty activity and redemption (e.g., loyalty status, participation, points earned/redeemed, etc.). 
Audio/Visual Information, such as photographs, images, videos, and recordings of Your voice (including when We record customer service calls).
Geolocation, such as information that allows us to determine Your location, such as if You provide Us with Your location information, We obtain estimates of geographic location (such as from IP address), or if You enable Your device to send us precise geolocation information. 
Internet or Other Network Activity 
technical data, such as browser information, browser size, smart device, sensor, browser version, operating system and version, device information/type, language setting, email client used; screen size/resolution, internet service provider, and network domain name.
browsing data, such as information related to Your use of Our Sites; where You came from, login details, location, data related to Your navigation of Our Sites (e.g., scroll, mouse movements), pages/ad/content You looked at, clicked, or tapped, creative shown, duration of Your visit, products You searched for and/or selected to create Your basket; and email messages opened and any links clicked-through.
Inferences, using personal information about an individual to create a summary about, for example, an individual’s preferences and characteristics, including beauty and related preferences, characteristics, behaviors on and off site, purchase patterns, demographics, household information
Marketing and Promotions:  We collect and use personal to:
send or show You tailored and personalized content, advertisements, offers, and other marketing communications (including by email, text message, postal mail, or online targeted advertising), including based on the personal information We know or learn about You, Your beauty and physical characteristics, health and medical information, user generated content, and Your preferences, 
show you marketing communications on other websites, including on social media and other websites, 
send content on Your behalf to Your friends and family (refer-a-friend programs); and 
manage any competitions, promotions, surveys, sweepstakes, giveaways, or contests You choose to enter.
 We share or make available personal information (such as identifiers, Internet or similar network activity, commercial information, inferences) with third parties (including marketing and advertising networks and social media platforms), including by using cookies (and similar technologies) on Our Sites, to serve You tailored and personalized advertisements, that is to show you (A) online advertisements for products that may be of interest to You, based on Your previous behaviour; and/or (B) ads and content on social media platforms or other websites and services and across other devices.  Please see “Additional Information about Our Advertising” for more details.  
For example, We may retarget You with messages based on actions You take on Our Site, such as cart reminder messages to finalize Your order where You have saved Your shopping cart or placed products in Your shopping cart without completing the checkout process.  Our Sites use cookies and other technologies to help keep track of items You put into Your shopping cart including when You have abandoned Your cart and this information is used to determine when to send cart reminders (including messages via SMS).
We use personal information we maintain about You and others (e.g., internet and network browsing information, basic identifiers, online identifiers, contact data, preferences data, physical characteristics, health and medical information, demographic data, user generated content, geolocation, inferences, commercial/purchasing information) to create audience segments comprised of identifiers so We can optimize and deliver advertising to You, including online (i.e., online advertisements for products or services that We believe may be of interest to You, based on Your previous behavior), and/or on social media platforms (e.g., Google, Meta, Snapchat, Amazon, Pinterest, TikTok).   For example, We will create what are known as ‘custom audiences’ by uploading an identifier You provided Us or We obtained (email, phone number, cookie or device ID, other identifier, etc.) to a platform that is selling advertisements (such as Facebook, YouTube, Instagram, Pinterest, etc.).   We can also use an identifier to serve You with advertising on websites that participate in online auctions of their ad inventory.     
Our Sites also use features provided by our advertising companies (such as Google or Facebook) to collect and share with them personal information you enter on our Site (such as a phone number or email address) in hashed form (e.g., Facebook “audience matching” or Google’s “enhanced conversions”).  We use this information to connect your account with these companies with Your activities on our Site to (i) enhance measurement of our advertisements and (ii) identify groups of alike customers to optimize our own marketing campaigns. 
Please note that often these companies use personal information they receive to improve their own products and optimize their own ad targeting systems.  
We add participation or engagement information with Our advertisements to Your profile so We can understand Your interests and preferences 
Personalized Content:  We use personal information We collect and store associated with You and others to assess and understand Your interests and Your preferences (e.g., inferences and derived data) to provide with personalized experiences.  This helps Us to: 
personalize recommendations, marketing, and content based on Your profile and interests; 
display our Sites in a tailored way (e.g., show you products We believe You might like); and 
personalize marketing and other communications You see or receive from Us.
Event Management:  Personal information is also collected and used for event planning and management, including registration, attendance, connecting You with other event attendees, and contacting You about relevant products and services. 
 
Identifiers:
basic identifiers, such as first and last name, alias, email, postal address, account name, signature, username, social media handle, or similar identifiers
online identifiers, such as device identifiers; internet protocol address (IP address), cookies, beacons, pixel tags, mobile ad identifiers, or similar identifiers. 
Other Personal Information: 
contact data, such as home address, shipping address, telephone number(s), mobile number(s), email address(es), etc. 
preferences data, such as subscription type (contact preference:  email, SMS; recurringorder/subscription information), date created, date modified, and permission status.
physical characteristics, such as personal descriptions, skin tone and type, hair color, eye color, and other beauty profile information You provide or We collect.
health and medical information, such as information regarding skin conditions (e.g., acne, rosacea) in connection with a beauty service, online or in-store experience, or product recommendation. 
user generated content, such as any content (e.g., text, videos, images, ratings and reviews, etc.) You create and/or provide to Us (e.g., via Your “My Account” page, contacting Us, using the chat function on Our Sites, using services available on Our Sites or stores, or by participating in a contest, game, survey, etc).   
Commercial or Purchasing Information, such as products or services (e.g., gift certificate) purchased, obtained, or considered (e.g., order details, transaction information, products added to cart, shipping/return status, store location); purchasing or consuming histories or tendencies; and loyalty activity and redemption (e.g., loyalty status, participation, points earned/redeemed, etc.). 
Characteristics of Protected Classes 
demographics, such as age, gender, race, ethnicity, and household information, some of which may include protected classifications under domestic law.     
biometric data, such as information considered biometric information or a biometric identifier under domestic law. 
Internet or Other Network Activity 
technical data, such as browser information, browser size, smart device, sensor, browser version, operating system and version, device information/type, language setting, email client used; screen size/resolution; Internet Service Provider, and network domain name; and 
browsing data, such as information related to Your use of Our Sites; where You came from, login details, location, data related to Your navigation of Our Sites (e.g., scroll, mouse movements), pages/ad/content You looked at, clicked, or tapped, creative shown, duration of Your visit, products You searched for and/or selected to create Your basket; and email messages opened and any links clicked-through.
Audio/Visual Information, such as photographs, images, videos, and recordings of Your voice.
Geolocation, such as information that allows us to determine Your location, such as if You provide Us with Your location information, We obtain estimates of geographic location (such as from IP address), or if You enable Your device to send us precise geolocation information. 
Inferences, using personal information about an individual to create a summary about, for example, an individual’s preferences and characteristics, including beauty and related preferences, characteristics, behaviors on and off site, purchase patterns, demographics, household information
User Generated Content.  We may offer You the ability to post content that others can read (directly or through a third-party service).  We collect and use personal information to: 
provide you with a forum for discussion, 
use Our services, 
to ask questions, and 
to use and post content You create and/or share with Us on Our Sites or in Our retail locations.     
For example, when you submit content on one of Our social media platforms or accept the re-use of content You posted on a social media platform by Us.  
Ratings and Reviews.  We collect and use personal information to post Your rating/review or content on the Sites, Our social media pages, and related third party websites that retail or feature Our brand and products, and to communicate with You. 
For example, You may submit reviews and comment on or rate goods, products, and services on our Sites.  In order to submit this information, You need to provide other information, such as Your name, email address, mailing address or phone number, and other personal information. We (and our third-party ratings & review provider) also use cookies (or similar technologies) to collect information to provide the service, enable the submission of user-generated content, and to analyse usage. 
We do add user generated content to the beauty profile We maintain about You to better understand Your interests and preferences. 
Please note, personal information You provide may be published on public-facing Sites or media and is accessible to others.  We do not have to publish any content You provide (in whole or in part). 
 
Identifiers: 
basic identifiers, such as first and last name, alias, account name, email address, postal address, signature, username, social media handle, or similar identifiers.
online identifiers, such as device identifiers; internet protocol address (IP address), cookies, beacons, pixel tags, mobile ad identifiers, or similar identifiers; and browser information. 
Other Personal Information 
contact data, such as home address, shipping address, telephone number(s), mobile number(s), email address(es), etc. 
physical characteristics or preferences, such as personal descriptions, skin tone and type, hair color, eye color, and other beauty profile information You provide or We collect.
user generated content, such as any content (e.g., text, photographs, videos, ratings and reviews, social media comments, etc.) You create and/or provide to Us or otherwise publicly post.   User-generated content may include other personal information You choose to include, such as purchasing information (i.e., products You considered or purchased), physical characteristics data, or information about health and medical conditions 
Audio/Visual Information, such as photographs, images, videos, and recordings.
Geolocation, such as information that allows us to determine Your location, such as if You provide Us with Your location information, We obtain estimates of geographic location (such as from IP address), or if You enable Your
Internet or Other Network Activity
technical data, such as browser information, browser size, browser version, operating system and version, device information/type, language setting, email client used; screen size/resolution inferred geographic location by IP address; internet service provider, and network domain name.
browsing data, such as information related to Your use of Our Sites, where You came from, data relating to Your navigation of Our sites (e.g., scroll, mouse movements), pages/ad/content You looked at, clicked or tapped, creative shown, and duration of Your visit.
Inferences, using personal information about an individual to create a summary about, for example, an individual’s preferences and characteristics, including beauty and related preferences, characteristics, behaviors on and off site, purchase patterns, demographics, household information
Financial Incentive Program Management.  We process personal information to implement and administer Our financial incentive (e.g., coupons, samples), rewards, and/or loyalty programs.  
For example, if you sign-up to receive a coupon or sample and provide Your name and contact details, a coupon or sample is sent to You.  We use third parties to help us provide these services, and we will receive personal information associated with Your participation (such as, for a coupon, basic identifiers, online identifiers, contact data, commercial or purchasing information (i.e., campaign name and ID, coupon code, action taken (view coupon, print coupon, redemption of coupon)); for a sample, basic identifiers, online identifiers, contact data, information about sample requested, ratings & review information associated with requested sample).  We and Our third party vendors use and analyze personal information to identify and detect fraudulent requests (including online data and technical and browsing data).  
For loyalty programs, this may include setting up and verifying Your account, communicating with You regarding the program, tracking rewards/points You earn pursuant to the terms of the financial incentive program, and providing You with benefits associated with this program.    
We may offer unique rewards provided by third parties.     We will facilitate exchange of loyalty points for products, promotional materials, and other items from such third parties.  To do so, we will need to disclose personal information about You (such as basic identifiers, contact information, commercial or purchasing information) with third parties to complete Your request.  
Refer-a-Friend Program.  We also process personal information (such as basic identifiers, online identifiers, contact data, commercial or purchasing information (reward type, reward redemption/fulfilled reward value), technical and browsing data) to provide refer-a-friend programs on some of our Sites.  This enables individuals on Our Sites to create either a code or send a communication to a friend or family.  If the friend or family member makes a purchase using the coupon code or by engaging with the communication received the referrer will receive a coupon or other reward.   We (and our third-party service provider) also use cookies (or similar technologies) to collect information to provide the service, detect and prevent fraud, and to analyse and measure usage.
Identifiers 
basic identifiers, such as first and last name, alias, email, postal address, account name, signature, username, social media handle, or similar identifiers
online identifiers, such as device identifiers, internet protocol address (IP address), cookies, beacons, pixel tags, mobile ad identifiers, or similar identifiers (order fingerprints), and browser information. 
Other Personal Information 
contact data, such as home address, shipping address, telephone number(s), mobile number(s), email address(es), etc. 
Commercial or Purchasing Information, such as information about preferred channel or store, loyalty status, loyalty participation subscription or recurring order-related information, gift certificate purchase; products considered or purchased (e.g., order details, transaction information, products added to cart, shipping/return status, store location), and other purchasing or consuming histories or tendencies.  
Internet or Other Network Activity 
technical data, such as browser information, browser size, smart device, sensor, browser version, operating system and version, device information/type, language setting, email client used; screen size/resolution Inferred geographic location by IP address; Internet Service Provider, and network domain name
browsing data, such as information related to Your use of Our Sites, where You came from, login details, location, data related to Your navigation of Our Sites (e.g., scroll, mouse movements), pages/ad/content You looked at or viewed, clicked, or tapped, creative shown, duration of Your visit, products You searched for and/or selected to create Your basket, and email messages opened and any links clicked through. 
For Security & Integrity, and to Detect and Prevent Fraud.  We use personal information We collect to:
Verify Your identity, and to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions, attempts to manipulate or violate our policies;
enforce our Terms of Use
conduct security investigations and risk assessments; 
verify or authenticate information provided by You; 
maintain the security and integrity of our products, services, Sites, and systems; and 
to otherwise protect Our rights, property, and safety, or the rights, property, and safety of others.  
Closed Circuit Television is used at warehouse and Our retail locations to identify and investigate theft or security concerns, while phone calls are recorded.  If you have an incident or medical issue while at one of Our locations, we may collect and use health and medical information to respond to such incident and for regulatory and compliance purposes. 
We analyse Your interactions with the Sites, Our services, or Our retail locations, Your profile information, and other personal information We obtain about You (including identifiers, payment information, commercial information, internet or other network activity information, geolocation, audio/visual information).  We also use solutions provided by third parties to analyze Your activities on Our Sites as well as information in relation to activities on and off Our Sites that can be associated with You, that could restrict or suspend access to Our Sites.  This process may be completed automated or may involve human intervention where a person makes a final decision.  
You may (i) experience delays in the processing of Your order/request while Your transaction is being reviewed; and/or (ii) be limited or excluded from the benefit of a service.
We will otherwise process personal information to protect Our rights and property, and the rights, property, and safety of others. 
Identifiers: 
basic identifiers, such as first and last name, alias, account name, signature, username, social media handle, or similar identifiers
online identifiers, such as device identifiers (MAC address); internet protocol address (IP address), cookies, beacons, pixel tags, mobile ad identifiers, or similar identifiers; and browser information. 
Other Personal Information: 
contact data, such as home address, shipping address, telephone number(s), mobile number(s), email address(es), etc. 
preferences data, such as subscription type (email, SMS), date created, date modified, and permission status.
user generated content, such as Your communications with Us and any other content you create or provide to Us. 
health and medical data (e.g., attendance/visitor forms may collect welfare/health data, data collected in the event of an incident at one of Our facilities). 
Demographic information, such as age, gender, race, ethnicity, and household information, some of which may include protected classifications under domestic law.     
Internet or Other Network Activity (
technical data, such as browser information, browser size, smart device, sensor data, browser version, operating system and version, device information/type, language setting, email client used; screen size/resolution Internet Service Provider, and network domain name 
browsing data, such as information related to Your use of Our Sites, where You came from, location inferred from IP address, data relating to Your navigation of Our sites (e.g., scroll, mouse movements), pages/ad/content You looked at, clicked or tapped, creative shown, and duration of Your visit. 
This also includes What You are doing on Your device, like if your mouse is moving (which can help Us (and our third-party service providers) tell humans from bots)
Audio/Visual Information, such as photographs, images, videos, and recordings of Your voice (including when We record customer service calls).
Commercial or Purchasing Information, such as information loyalty status, loyalty participation (points earned/redeemed), gift certificate purchaser (e.g., sender name, recipient name, recipient email, message); products considered or purchased (e.g., order details, transaction information, products added to cart, shipping/return status, truncated payment card, payment method, store location), and other purchasing or consuming histories or tendencies.  
Geolocation, such as information that allows us to determine Your location, such as if You provide Us with Your location information, We obtain estimates of geographic location (such as from IP address), or if You enable Your device to send us precise geolocation information. 
Inferences, using personal information about an individual to create a summary about, for example, an individual’s preferences and characteristics, including beauty and related preferences, characteristics, behaviors on and off site, purchase patterns, demographics, household information
Verify or Maintain Quality or Safety of Our Products and Services; Product Improvement.  We use personal information collected to understand how our products, services, facilities, and Sites are used, and to validate metrics to inform and improve our products, services, facilities, and Sites. 
We use personal information We have collected, including through consumer surveys, call logs and call recordings, other market research activities, and from an analysis of how our Sites, products, facilities, and services are used (including via cookies (and other similar technologies) on Our Sites), to develop, research, and test improvements to our Sites, products, and services.  We use personal information to: 
understand how You interact with Our Sites and advertisements (including to avoid visitors being counted twice), 
conduct auditing and monitoring of transactions and engagements;
counting ad impressions, verifying positioning and quality of Our ads; 
to see if a product or service is working and troubleshoot and correct if it is not; 
to improve the effectiveness of Our Sites, stores, customer service, and product offering, and communications, 
to test out new products, services, and features; 
obtain feedback;
conduct surveys and other research about what Our customers may like and what We can do better; 
develop new products and services; and 
for research and innovation by scientists within the Beetles, including undertaking internal research for technological development and demonstration.   
Our Sites use cookies (and similar tracking technologies), including from Google Analytics and Glassbox, which allow Us to count visits and traffic sources and understand what pages are the most and least popular.  They also help Us track and replay a visitor’s journey on Our Sites.  These tools help Us understand how visitors move around and interact with Our Sites so We can measure and improve Our Sites.    These technologies also help Us to understand when visitors have taken certain actions.  For example, we can see how frequently buttons on Our Site have been clicked and which products are reviewed or purchased.  It also helps Us understand how many visitors have come to Our Sites after engaging with Our ads and what actions they take.
Additionally, in Our retail stores
We may use the data collected from these in-store wireless services to provide operational insights such as foot traffic volumes and how customers move through Our stores to improve the layout of Our stores and offer products that most interest Our customers.
Publicly Posted Content.  Additionally, we collect and use personal information publicly available, including information publicly posted on social media platforms, or when You mention Us on social media platforms (such as social media handle, photo, and/or any comments mentioned in Your post), to better understand how consumers view Our products/services and interact with Us (e.g., social listening -We may use public social media posts to identify beauty trends)
Identifiers:
basic identifiers, such as first and last name, alias, account name, email, postal address, signature, username, social media handle, or similar identifiers
online identifiers, such as device identifiers; internet protocol address (IP address), cookies, beacons, pixel tags, mobile ad identifiers, or similar identifiers; and browser information. 
Other Personal Information 
contact data, such as home address, shipping address, telephone number(s), mobile number(s), email address(es), etc. 
preferences data, such as subscription type (contact preferences:  email, SMS; shopping preferences), date created, date modified, and permission status.
physical characteristics, such as personal descriptions, skin tone and type, hair color, eye color, and other beauty profile information You provide or We collect.
health and medical data, such as medical conditions regarding skin conditions (e.g., acne, rosacea) in connection with a beauty service, online or in-store experience, or product recommendation. 
user generated content, such as Your communications with Us and any other content you create or provide to Us (e.g., ratings and reviews, communications with Us, responses to surveys) 
Commercial or Purchasing Information, such as information about preferred channel or store, loyalty status, loyalty participation (points earned/redeemed), subscription or recurring order-related information, gift certificate information (e.g., sender name, recipient name, recipient email, message, redemption/value); products considered or purchased, and other purchasing or consuming histories or tendencies.  
Characteristics of Protected Classes 
demographic data, such as age, gender, race, ethnicity, and household information, some of which may include protected classifications under domestic law     
biometric data, such as information considered biometric information or a biometric identifier under domestic law. 
Internet or Other Network Activity 
technical data, such as browser information, bowser size, smart device, sensor data, browser version, operating system and version, device information/type, language setting, email client used; screen size/resolution, inferred geographic location by IP address; internet service provider, and network domain name
browsing data, such as information related to Your use of Our Sites; where You came from, login details, location, data related to Your navigation of Our Sites (e.g., scroll, mouse movements), pages/ad/content You looked at, clicked, or tapped, creative shown, duration of Your visit, products You searched for and/or selected to create Your basket; and email messages opened and any links clicked-through
Audio/Visual Information, such as photographs, images, videos, and recordings of Your voice (including when We record customer service calls).
Geolocation, such as information that allows us to determine Your location, such as if You provide Us with Your location information, We obtain estimates of geographic location (such as from IP address), or if You enable Your device to send us precise geolocation information. 
Inferences, personal information about an individual to create a summary about, for example, an individual’s preferences and characteristics, including beauty and related preferences, characteristics, behaviors on and off site, purchase patterns, demographics, household information
 
Additional Information About Our Advertising (including Interest-Based Advertising):  We provide tailored and personalized content, services, advertisements and offers, including based on personal information We know about You as well as Your beauty characteristics and preferences.  
When We send or display personalized communications or content, We use personal information to generate inferences about You.   We use these inferences to show You advertisements or other content We believe You would like to see.  This means We collect personal information about You as described above, and We centralize this personal information and analyze it to evaluate and attempt to determine Your personal preferences, interests, or needs.   For example, based on information We collect We may conclude that You are interested in certain products and services We provide and then We send or display communications or content tailored to those preferences, interests, or needs.  
We may recognize Your information across different devices that You use or log in from (i.e. computers or mobile devices.). We may recognize that one cookie or device ID (i.e. from a computer) may be connected to another device (i.e. smart phone) by the cookie or device ID or log in. This may result in You searching for one of Our products on one device but seeing an ad later for that product on another device. Knowing what devices are being used by a person or household helps Us limit the number of times You may see the same ad across different devices.  We may also combine information We collect from Your devices with other information We have about You, such as Your account information, services, transaction history, and interaction with Our Sites.
We participate in interest-based advertising.  We use third party companies to serve advertisements tailored to Your individual interests based on how You browse and shop online, as well as to provide advertising-related services such as measuring the performance and engagement with Our ads, provide analytics, preference, and interest information. In some instances, these ad network providers, social platforms, sponsors, and/or analytics providers may use their own tracking technology to capture information about Your device, use, and engagement online for the purpose of tailoring advertising (for Our products or for products or services of other companies) based on preferences or interests known or inferred from the data collected.  We use Google Analytics Advertising Features to share information with Google about Your use of this site to allow Us to deliver relevant and personalized advertising or content to You on other websites.  We have enabled the following Google Analytics Advertising Features:  Remarketing with Google Analytics (which allows Us to create an audience of users based on user behavior on Our Sites,   so We can use that audience to deliver Our advertisements (e.g., a user who viewed a product but did not add to cart may receive an advertisement for that item, while a user who added items to their cart but didn’t complete the purchase may receive an ad for the item left in the cart), Google Display Network Impression Reporting, Google Analytics Demographic and Interest Reporting, and integrated services that require Google Analytics to collect data for advertising purposes, including collecting data via marketing cookies and identifiers.  These companies will use personal information they receive to improve their own products and optimize their own ad targeting systems. 
Other Purposes.  We collect and use any personal information We collect for other legitimate purposes, such as our day-to-day business operations, to analyze and improve our business, for corporate governance, and to comply with laws and regulations.  For these purposes, we may use any categories of personal information collected by Us.   
Day-to-Day Business Operations & Product Improvement.  We use personal information we have collected for other purposes reasonably required for day-to-day operations, such as accounting, collecting payments due and owing to Us, financial reporting, business analytics, operational and strategic business planning, real-estate management, and expense management.  
Corporate Governance.  We also use any personal information we collect for planning, managing, and carrying out restructuring, redundances, or other change programs, evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolving, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information by Us is among the assets transferred.  
Compliance with Laws & Regulations.  We use personal information We collect to comply with local laws; enforce Our legal rights and obligations; and for any purpose in connection with legal claims, reports of violations, or allegations made by, against, or otherwise involving, and to the otherwise comply with lawful requests by public authorities, e-discovery requests or where otherwise required or permitted by applicable laws, court orders, government regulations, or regulatory authorities.  
How We Share Personal Information
Third Parties Providing Services On Our Behalf:  
We rely on third parties to perform a range of business operations on Our behalf. Service providers may also use personal information for their own internal business purposes, such as process or product improvement.  For instance:
Third parties that assist and help Us in providing digital and e-commerce services such as social listening, store locator services, loyalty programs, quizzes and product finders, name collection and lead generation, identity management, ratings and reviews, teleconsultations tools and services, product recommendations, predictive sort, product search, personalized services, virtual try-on tools, coupons, loyalty, refer-a-friend program management, customer relationship management, data management tools, provide subscription or recurring purchases, gift cards purchase and redemption, sampling and redemption services; web chat features, and user generated content curation tools; 
Advertising, marketing, digital and social media agencies, analytics providers, and vendors to help Us to deliver advertising, marketing, and campaigns, to analyze their effectiveness, understand how consumers use Our Sites, products and services, and Our retail locations, and to manage Your contact and questions.  For example, providers that:
help Us send Our direct mail, email, and SMS marketing messages, 
personalize Our Sites, 
help Us manage Our events, 
deliver Our ads (e.g., demand side platforms, ad servers, content optimization), and 
analyze Our customers.
Third parties that assist and help Us in providing IT services, such as platform providers, hosting services, master data management, maintenance and support on Our databases as well as on Our software and applications that may contain data about You;
Third parties that provide us with consulting services in the field of market research and analytics, and who help Us collect feedback on our products and services; 
Third parties that assist Us with bot and fraud detection and prevention, legal, compliance, and risk management; 
Third parties that provide order processing, fulfilment, shipping, and return management; provide delivery and shipment notifications, who process transactions and payments; provide customer service and support, and assess customer satisfaction; 
Third parties that assist Us for customer care and cosmetovigilance purposes.
Categories of personal information shared (depending on the specifics of the business transaction) with these third parties include identifiers, internet or network activity, geolocation data, purchasing information, protected classifications, professional or employment-related information, audio-visual information, other categories of personal information, biometric, geolocation information, payment information, other information, and inferences generated from the foregoing categories of information.
Transactions You Have Requested or to Which You Have Agreed
Personal information may also be shared to complete a transaction You requested.  For example, payments You make to pay for goods and services through some of Our Sites are completed using a third party’s online payment system (e.g., Apple Pay, PayPal).  Additionally, You may elect to use buy now pay later services available on Our Sites (e.g., Afterpay) or receive free shipping through third party services (e.g., ShopRunner).  To facilitate Your request, categories of personal information such as identifiers, internet or similar network activity, contact information, and purchasing information is shared to complete the transaction You requested.  
Additionally, some of Our Sites may provide the opportunity to post content in a public forum or provide user generated content.  For example, providing ratings & reviews about Our products and services, granting Us permission to host user-generated content; posting on Our social media pages or channels; or participating in contests, blogs, or videos.  This content is intended for public consumption, and we may display this content. Once displayed publicly that information can be collected and used by others. If You decide to submit information or permit Us to post it in these public forums, the information will be publicly available. 
Other Third Parties (Ad Networks and Advertising Companies):
We share or make available personal information (such as identifiers, Internet or similar network activity, commercial information, inferences) with third party marketing and advertising networks and social media platforms to serve You tailored and personalized advertisements on other websites and services and across other devices.  For example, when You provide Us with personal information, We use that information to optimize our advertisements, serve You advertisements, and measure advertisement performance.  We do this generally by uploading an identifier You provided Us or We obtained (email, phone number, cookie or device ID, other identifier, etc.) to a platform that is selling advertisements (such as Facebook, YouTube, Instagram, Pinterest, etc.).   We can use that same data to serve You with advertising on websites that participate in online auctions of their ad inventory.  
Additionally, when You visit Our Sites We use cookies (or other similar technologies) from third parties.  Information collected by these companies is used to build a profile of Your interests to show You relevant advertising on other websites or to other devices connected to You (cross-device advertising) by Us or other companies, and includes identifiers, internet or network activity, commercial information, and inferences generated from the foregoing.  In connection with advertising or Our Sites, You may be asked to receive information and/or marketing offers from someone else, or to otherwise agree to the sharing of Your information with a third party.  
Some of Our Sites have features such as plugins, widgets, or other tools provided by third parties.  These tools collect identifiers along with internet or similar network activity (e.g., IP address and what page You are visiting).  If You engage with such plugins, widgets, or other tools, additional information may be shared.  For example, if You use Facebook’s “like” feature, Facebook may register the fact that You ‘liked’ a product and may post that information on Facebook.  This use of information is not governed by Our privacy notice.  
These companies use personal information they receive to improve their own products and optimize their own ad targeting systems.  
Business Transfers: 
As We continue to develop Our business, We (or Our affiliates) may sell or purchase assets, or otherwise be acquired by, merged with, or invested in by another company. If another entity acquires Us or Our assets, or assets related to the Sites or Our business, personal information, and any other information that We have collected may be disclosed to such entity as one of the transferred assets. We may also share certain personal information as necessary prior to the completion of such a transaction or corporate transactions such as financings or restructurings, to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for a transaction.  If any bankruptcy or reorganization proceeding is brought by or against Us, all such information may be considered an asset of Ours and as such may be sold or transferred to third parties. 
Legal Disclosure; Security and Protection of Rights: 
Beetles may transfer and disclose information, including personal information about You, and any other information that We have collected, to third parties to comply with a legal and compliance obligation; when We believe in good faith that the law requires it; or at the request of governmental authorities conducting an investigation. For example, We may disclose personal information in response to subpoenas, courts orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.  This may include regulators, government entities, and law enforcement.  In addition, it may include certain disclosures that We are required to make under applicable laws, such as making available (including to the public) names of sweepstakes or contests winners. 
We may disclose personal information where We believe doing so is necessary to protect the services, Sites, Our rights and property, or the rights, property, and safety of others.  For example, We may disclose personal information to (i) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the services and Sites; (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party; or (iii) enforce, and detect, investigate, and take action in response to, violations of Our Terms of Use.  We may also disclose personal information related to litigation and other legal claims or proceedings in which We are involved, as well as for Our internal accounting, auditing, compliance, recordkeeping, and legal functions. 
How Long Do We Retain Personal Information?
In accordance with Our routine record keeping, We may delete certain records that contain personal information You have submitted through the Sites. We are under no obligation to store such personal information indefinitely and disclaim any liability arising out of, or related to, the destruction of such personal information. In addition, You should be aware that it is not always possible to completely remove or delete all information about You from Our databases without some residual data because of backups and other reasons.
We will retain personal information about You for as long as Your account is active, You engage with Us, as needed to provide You services, and as necessary to comply with Our legal and/or regulatory obligations, to resolve disputes, to manage Our rights, and to enforce Our agreements. 
We do not control certain privacy settings and preferences maintained by Our social media partners like Facebook and Twitter. If You wish to make changes to those settings and preferences, You may do so by visiting the settings page of the appropriate social media site.
Your Privacy Choices
               Email:
You may change Your preferences and unsubscribe from email services from Our brands by: (i) modifying Your registered user information on the Sites; (ii) sending Us an e-mail to the address listed in Contact Us located at the end of this Notice; or (iii) following the unsubscribe instructions in the communications that You receive.  
               SMS Text Messages:
We may send text messages if You have agreed to receive from one of Our brands.  You may cancel text messages from a brand at any time by texting “STOP”.  After You send “STOP” We may send You an additional text message to confirm that You have been unsubscribed.  If at any time You have questions about the text messages please text “HELP”.  Message and data rates may apply.
               Push Notices; Uninstallation of Mobile Apps:  
You may at any time opt out from push notifications or allowing Us to access location data by adjusting the permissions in Your mobile device.  Some features on the Sites may require access to the camera or other features of Your device.  You can adjust the settings or Your device to control access to the camera or other features.   You can stop all further collection of information by Our mobile applications by uninstalling the mobile application.  Please note that if You uninstall the mobile application from Your mobile device, the unique identifier associated with Your mobile device will continue to be stored.  If You re-install the application on the same mobile device, We will be able to re-associate this identifier to Your previous transactions and activities.
               Geo-Location and In-Store Location:
You may prevent Your mobile device from sharing Your location data by adjusting the permissions on Your mobile device or within the relevant app. &
               Cookies, Tracking, and Interest-Based Advertising:
If You would prefer not to accept cookies, You can manage Your cookie preferences by clicking on the “Cookie Settings” link located on the bottom of the website homepage.   You cannot disable essential cookies.  You can also change Your browser settings to notify You when You receive a cookie, which lets You choose whether or not to accept it; or set Your browser to automatically reject any cookies. However, please be aware that some features and services on Our Sites may not work properly because We may not be able to recognize and associate You with Your account. In addition, the offers We provide when You visit Us may not be as relevant to You or tailored to Your interests. To learn more about cookies, please visit https://www.allaboutcookies.org
You can opt out of receiving targeted advertising through the Network Advertising Initiative (NAI) Opt–Out Page or the Digital Advertising Alliance Opt-Out page. Options are Device-specific, so if You use multiple devices, You should opt out on each one. You can also opt out of certain targeted advertising programs by clicking on the AdChoices icon that appears on Our Site footers and may appear on Our advertising. Even if You opt-out of targeted advertising, You may still see Our advertisements while You are browsing, but they may not be targeted to You based on Your interests.
Some social networks (such as Facebook), allow You to exercise ad choices, limit data collection and clear Your history on that platform as well.
               Do Not Track (“Global Privacy Control”):  
Under the laws of several areas, Website and online service operators are required to disclose how they respond to web browser ‘do not track’ signals.  Beetles does not currently take actions to respond to Do Not Track signals as a uniform standard for such response has not yet been established.  However, where required by law, We will treat browser-based signals such as the Global Privacy Control as requests to opt-out of the sale/sharing of personal information.
               Other Analytics Services:  
We use certain analytics services, such as Google Analytics, to gather information about Our site visits or mobile app usage.   We also use Google Analytics Advertising Features to share information with Google about Your use of this site to allow Us to deliver relevant and personalized advertising or content to You on other websites.  We have enabled the following Google Analytics Advertising Features:  Remarketing with Google Analytics, Google Display Network Impression Reporting, Google Analytics Demographic and Interest Reporting, and integrated services that require Google Analytics to collect data for advertising purposes, including collecting data via marketing cookies and identifiers. You can learn more about how Google Analytics processes information here: Google Analytics Terms of Use and Google Privacy Policy.  You can also download and install the Google Analytics browser plugin available here  that allows You to disable Google Analytics across all websites.  To learn more about Google Analytics, including opting out of Google Analytics, click here.
In connection with analytics used in our retail locations, You may opt-out of having a mobile device counted in statistics.  You may opt-out by visiting this website.  
Privacy Rights Under Domestic Law
Rights Available Under Domestic Law
Depending on Your area of residency, you may be able to exercise the following rights in relation to personal information about you that we have collected (subject to certain limitations under local law).  These may include:  
Right to Know.   The right to request that We disclose information about our collection and use of Your personal information, including:
Categories of personal information We collected
Categories of sources for the personal information We collected
Our business or commercial purpose for collecting personal information
The categories of third parties with whom We share that personal information
The specific personal information We collected about You
Right to Access and Portability.  The right to confirm whether We are processing personal information about You and to obtain a copy of such personal information we have collected about you, and, where required by law, obtain a copy of such personal information in a portable and, to the extent technically feasible, readily usable format. 
Right of Deletion.  To delete personal information provided to or obtained by Us.  You have the right to request that We delete personal information about You, subject to certain exceptions and to the extent required by law. Once We receive and confirm Your verifiable consumer request, We will delete personal information about You from our records, unless an exception applies.
For example, personal information may need to be kept to:
Complete a transaction for which We collected the personal information, provide a good or service requested (such as the sale of our beauty products to You), or reasonably anticipated within the context of a relationship with Us, 
Track consumer complaints or product issues
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity
Comply with a legal obligation
Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us
Other internal uses compatible with the context in which the consumer provided US with personal information 
Right of Correction.  The right to correct inaccuracies in personal information, taking into account the nature and purposes of the processing of personal information. 
The Right to Control over Sensitive Personal Information.   Depending on Your Area of residence, You have the right to ask that we limit our use and disclosure of Sensitive Personal Information to certain purposes permitted by law and/or revoke consent to Our use of Sensitive Personal Information.    
Right to Opt-Out.  Depending on Your Area You have the right to  opt-out of certain types of processing of personal information, including: 
To opt-out of the ‘sale’ of personal information or sharing or use of personal information for targeted advertising
To opt-out of any processing of personal information for purposes of making decisions that produce legal or similarly significant effects.  
Depending on your area of residence, you may also have additional rights, such as (A) the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights; and (B) the right to request an appeal in the event We decline to take action on Your request.  If You would like to appeal any decisions regarding Your privacy rights, please contact Us at customersupport@beetlesgel.com.  
How to Exercise Privacy Rights Available Under Domestic Law (Access, Correct, Delete)
To submit Your data subject privacy request click here or contact Us using the toll-free number in How to Contact Us.
Only You or a person that You authorize to act on Your behalf, may make a request related to Your personal information. You may also make a verifiable consumer request on behalf of Your minor child.
The verifiable consumer request must:
Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative of the person who wishes to make a request.
We may not be able to respond to Your request or provide You with personal information if We cannot verify Your identity or authority to make the request and confirm the personal information relates to You or if we are unable to locate You in our systems.  Making a verifiable consumer request does not require You to create an account with Us.  We will ask You for the email information that You used to interact with Us or sign up for a loyalty, email, or to make purchases along with other information You submit (such as contact information like name, address, phone number) and the information We have in Our systems, to help verify Your identity or authority to make the request and confirm that Your information is in Our system. Information provided to submit a request will only be used in connection with the request.  We may ask you to provide additional personal information so that we can properly identify You.  If you choose not to provide this information, we may only be able to process Your request to the extent We are able to identify You in Our systems. 
We will endeavor to respond to a verified consumer request within 45 days.  If We require more time, We will inform You of the reason and extension in writing (including by email).
We do not charge a fee to process or respond to a verified consumer request unless it is excessive, repetitive, or manifestly unfounded.  If We determine that the request warrants a fee, We will provide explanation and a cost estimate prior to completing the request.
You may only make a request for access or data portability twice within a 12-month period.
How to Exercise Rights Available Under Local Law (Sales of Personal Information & Sharing or Use of Personal information for the Purpose of Targeting) 
To exercise the right of opt-out in connection with a (1) a ‘sale’, (2) a ‘share’ or ‘use’ of personal information for targeted advertising, or both, where available in your jurisdiction please use one or more of the following: 
visit the “Your Privacy Choices” link on the footer of a brand Site to submit a request regarding offline (non-browsing) personal information. You may also click here to directly access our form or contact Us using the toll-free number in How to Contact Us
click on “Cookie Settings” link on the footer of a brand Site and change the setting regarding online (browsing) personal information.  
enable a browser-based opt-out signal such as the Global Privacy Control.  Where required to recognize such signals by applicable law We will treat the browser-based signals such as the Global Privacy Control as requests to opt-out of the sale/sharing or use of personal information for targeted advertising for your browser. If you are logged-in to Your account (where available), We will associate the browser-based opt-out signal with your account and apply it to offline personal information.  If you are not logged-in to Your account, the browser-based opt-out signal is only associated with that browser.
We may ask for information necessary to complete the request, such as information we need to identify the consumer whose information is the subject of the opt-out request.  
How to Exercise Rights Available Under Local Law (Sensitive Personal Information) 
Depending on Your area of residence, You may opt-out of certain uses of sensitive personal information by Us, including Our sharing of this type of personal information with third parties, and/or revoke consent previously given.  This opt-out will generally provide You with the ability to limit Our use of sensitive personal information to only the following (where permitted by applicable law): 
To perform services or provide goods reasonably expected by the consumer who requested the services or goods; 
To prevent, detect, and investigate security incidents; 
To resist malicious, fraudulent, deceptive, or illegal actions; 
Ensure the physical safety of natural persons;
Short-term, transient uses;
To perform services on Our behalf;
To verify or maintain the quality or safety of a product, service, or device owned, manufactured, manufactured for, or controlled by Us, and to improve, upgrade, or enhance such product, service, or device; and
For purposes that do not infer characteristics about a consumer.  
If You would like to opt-out of uses of sensitive personal information (or revoke a previously given to Our use of sensitive personal information), other uses otherwise permitted by applicable law, please submit Your submit Your request by clicking “Your Privacy Choices” link at the bottom of Our Sites. You may also click here to directly access our form or contact Us using the toll-free number in How to Contact Us.  
Authorized Agent Request 
You may designate an agent to submit requests on Your behalf.  We will need the agent to provide Us with Your signed permission to act on Your behalf.   For example, a Power of Attorney under the laws of the relevant jurisdiction from You or Your authorized agent.   Where permitted, We may also require You to provide proof You provided the authorized agent signed permission to act on Your behalf, and to verify Your identity with Us directly.  
Children’s Information
CHILDREN: Our Sites are not directed to children under 13. We do not knowingly collect, use or disclose personal information from anyone under 13 years of age. If We determine upon collection that a user is under this age, We will not use or maintain his/her personal information without the parent/guardian's consent. If We become aware that We have unknowingly collected personal information from a child under the age of 13, We will make reasonable efforts to delete such information from Our records. If You believe that We might have any information from or about a child under age 13, please contact Us through one of the methods listed in the Contact Us section at the end of this notice.
Parental Consent: Minors between 13 years of age and the age of majority in their area must ask their parent or guardian for permission to use any Beetles properties. For Beetles brand offering e-commerce, You may only make purchases if You are 18 years of age or older, or the age of majority in Your jurisdiction of residence.
Parental participation: We strongly recommend that minors 13 years of age or older ask their parents for permission before sending any information about themselves to anyone over the Internet and We encourage parents to teach their children about safe internet use practices.
Securing Personal Information About You
Beetles maintains reasonable safeguards to protect personal information against loss, unauthorized use, disclosure, or destruction and when transferring information for processing and requires third parties providing services on Our behalf to do the same. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that We cannot ensure or warrant the security of any information You transmit to Us.
Third Party Links; Social Login
The Sites may contain links to third party websites that are not owned or operated by Beetles. This includes links from advertisers, sponsors and/or partners that may use Our logo(s) as part of a co–branding or co–marketing agreement. We do not control, recommend, or endorse, and are not responsible for these websites or their content, products, services or privacy policies or practices. These other websites may send their own cookies or other tracking technologies to Your device; they may independently collect data or solicit personal information and may or may not have their own published privacy policies. You should also independently assess the authenticity of any site, which appears or claims that it is one of Our Sites (including those linked to through an email or social networking page). The Sites may make available chat rooms, forums, message boards, and news groups. Remember that any information that You disclose in these areas becomes public information and is not subject to the provisions of this Privacy Notice.
We may also offer You the opportunity to use Your social media login. If You do so, please be aware that You share Your profile information with Us depending on Your social media platform settings. Please visit the relevant social media platform and review its privacy policy to understand how Your personal information is shared and used in this context.
Cross-Border Transfers
The Sites are governed by and operated in, and in accordance with the laws of, the United Kingdom, and are intended for the enjoyment of residents of the United Kingdom. Country or region-specific websites are available for Beetles brand and products around the world. Beetles makes no representation that the Sites are governed by or operated in accordance with the laws of any other nation. Given that We are an international business, Our use of Your information necessarily involves the transmission of data on an international basis. By using the Sites, or providing Us with any information, You (a) acknowledge that the Sites are subject to the laws of the United Kingdom, (b) consent to the collection, processing, maintenance and transfer of such information in and to the United Kingdom and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where You reside and/or are a citizen, and (c) waive any claims that may arise under those laws. 
Updates to this Privacy Notice
Please note, We may change information on the Sites and/or this Privacy Policy at any time and any changes will be effective immediately upon the publication of revisions.
How to Contact Us
If You have any questions about Privacy, please contact Us at: Monday - Friday (9:00 AM - 5:00 PM EST) *On the business day, we will back to you within 24 hours. 
E-mail: customersupport@beetlesgel.com
Tel: +1-617-895-5722
TikTok: @beetlesgelpolishofficial
Facebook: @beetlesgelpolishofficial
Instagram: @beetlesgelpolish
Pin: @beetlesgelpolishofficial
Or send us an e–mail with your request here.
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