VOIR INC.
Privacy Policy
Effective Date: 30/12/2019
Welcome to Voir Inc., an innovative software that uses complex proprietary artificial intelligence technology (neutral networks and computer vision algorithms) to create digital makeup on the photo an real-time video (including amongst others accessories and hair colors). Our tech is created to provide a true-to-life virtual try-on experience for a wide range of beauty products. Specifically, we serve brands and retailers by helping them deliver a personalized experience for their customers in order to simplify their communication and increase sales.
VOIR Inc. believes that the privacy and security of our visitors and clients' information are of utmost importance. As such, we administer commercially reasonable policies safeguarding your privacy and security. This Privacy Policy explains how VOIR Inc. ("VOIR" or "company" or "we" or "us" or "our") and some of the companies we work and/or cooperate with collect, store, use, transfer, disclose and protect information and/or Personal Data from our users ("you") in relation to our VOIR mobile application (the "App"), website and any software provided on or in connection with VOIR and other related services (collectively, the "Services") as well as your choices about the collection and use of your information.
We reserve the right to and may change this Privacy Policy from time to time. If we make any material changes, for example, add new processing activities or collect some additional Personal Data from you, we will notify you by email (sent to the email address specified when you register) and/or through the App, and/or by presenting you with a new version of this Privacy Policy for you to accept.
Your continued use of the App after the effective date of an updated version of the Privacy Policy will indicate your acceptance of the Privacy Policy as modified. In some cases, you will have to explicitly accept changes to Privacy Policy to continue using the App. We encourage you to periodically review our website and the App for the latest information on our data privacy practices. If you do not accept the terms of the Privacy Policy, we ask you not to use the App. Please exit the App immediately if you do not agree to the terms of this Privacy Policy.
1. Information we collect from you
Personal Data you provide us through Services and the App include:
- Full name (if you provide us with it via e-mail);
- Email Address or any other contact (if you contact us or leave a feedback).
Information we automatically collect when you access or use the App:
-Device Information: we collect information about the hardware model and operation system of the mobile device you use to access the App;
-Location: we collect information about the country where you are using the App;
-App Usage statistics (i.e. sessions): we collect information about your use of the App, such as frequency of use, which areas and features of our App you visit and your use patterns generally, engagement tracking with particular features, etc.;
-Technical identifiers: we collect your install ID, which is a unique identification parameter that is generated based on your device's configuration when you access the App. This parameter does not contain any information about you or your device that can be used to identify you;
-Your face's color type: we collect your face's color type only if you have passed face scan. App can detect maximum four types, so this information can not be used to identify you.
We do not collect any information which identify or allows to identify you, unless you voluntarily provide us with such data (in particular, when communicating with our support team, leaving feedback about your experience with the App). If you provide us with your personal data voluntarily, we delete it after purposes for which they were provided to us are reached. Please note that to enable Apps' functionalities we shall need your camera to be turned on, as Apps' functionalities are based on computer vision algorithms. However, all images or other data caught by the camera, including facial data (landmarks, face pose, estimated 3D face mesh), shall be processed solely on your device and shall not be sent to our servers, i.e. we shall have no access to such images and data.
If the information covered by this Section is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose. To the extent information covered by this Section is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection laws, it is referred to in this Privacy Policy as "Personal Data". We use pseudonymization for particular types of Personal Data. Please bear in mind that provisions of Section 4 do not apply to pseudonymized Personal Data.
Please note that Apps' face detection algorithms are not able to identify a specific person and, therefore, generally cannot be considered as collecting biometric information. HOWEVER, IN CASE THE APPLICABLE LAW STIPULATES THAT IMAGES CAPTURED BY THE CAMERA OR FACE GEOMETRY GENERATED BY APPS ARE CONSIDERED AS BIOMETRIC IDENTIFIERS, BIOMETRIC INFORMATION OR SIMILAR LEGAL CATEGORY, HEREBY YOU EXPRESS YOUR INFORMED WRITTEN CONSENT ON THEIR PROCESSING, AS DESCRIBED IN THIS POLICY.
2.How we use your Personal Data and information we collect from you
| Information |
The purpose for processing |
| Full name |
to send you technical notices, updates, security alerts and support and administrative messages |
| Email Address or any other contact |
to send you technical notices, updates, security alerts and support and administrative messages |
| Your face's color type |
to improve the effectiveness of our Service |
| Device Information |
to diagnose or fix technology problems |
| Location |
to improve effectiveness of our Service and targeting of the App advertising
|
| App Usage statistics (i.e. sessions) |
to provide, improve, test, and monitor the effectiveness of our Service;
to develop and test new products and features;
to monitor metrics such as total number of visitors, traffic, and usage patterns (including via third party services as specified in Section 5 of this Privacy Policy);
to diagnose or fix technology problems |
| Technical identifiers |
to diagnose or fix technology problems;
to send you technical notices, updates, security alerts and support and administrative messages |
In case you voluntarily provide us with any personal data, we shall process these data solely for the purposes for which they were provided to us.
We will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you in accordance with Section 2 of this Privacy Policy or collect any Personal Data that is not required for the mentioned purposes ("purpose limitation principle"). To the extent necessary for those purposes, we take all reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We also undertake to collect only such amount and type of Personal Data that is strictly required for the purposes mentioned in this Section of the Privacy Policy ("data minimization principle").
3. Your Consent
By accessing the App, you explicitly consent that:
WE MAY STORE AND PROCESS YOUR PERSONAL DATA YOU PROVIDE THROUGH THE USAGE OF THE APP AND/OR WEBSITE SOLELY FOR THE PURPOSE OF PROVIDING SERVICES TO YOU, TO IMPROVE OUR SERVICE FEATURES AND OTHER PURPOSES INDICATED IN SECTION 2 OF THIS PRIVACY POLICY. TO ANALYZE THE APP USAGE STATISTICS WE MAY ALSO USE SERVICES PROVIDED BY THIRD-PARTY ORGANIZATIONS IN ACCORDANCE WITH SECTION 5 OF THIS PRIVACY POLICY.
4. Your Rights
- Modification and correction: You are able to modify, correct and erase your information you provided us by writing us at support@voir.me.
- Access: You have a right to access your Personal Data you leave when using the Services and ask us about what kind of Personal Data we have about you. You can do this by using the app settings or by writing us at support@voir.me.
EU residents have certain statutory rights with respect to Personal data we process in relation to their personal data introduced by the General Data Protection Regulation (the "GDPR"). But as we do not collect any information that identify or allows identifying you, some of stated in the GDPR rights may not be exercised by you (for example, right to erase your personal data, right to object processing your Personal Data).
- Rectification of Personal Data and Restriction of Processing: You are responsible for ensuring the accuracy of your Personal Data that you submit to VOIR. Inaccurate information will affect your experience when using the Services tools and our ability to contact you as described in this Privacy Policy. If you believe that your Personal Data is inaccurate, you have right to contact us and ask us to correct such Personal Data as described above. You shall also have the right to obtain restriction of processing of your Personal data, if you contest the accuracy of the Personal Data and we need some time to verify its accuracy.
- Access to your Personal Data and Data Portability: You shall have the right to request information about whether we have any Personal Data about you, to access your Personal data (including in a structured and portable form) by writing us at support@voir.me.
- Notice about automated decision-making: We may use automated decision-making tools (e.g. neural networks) that process your Personal Data in order to provide you better Services (for example, improvement of filters application).
- Notification requirements: We commit to notify you promptly and your data protection authority within the timeframe specified in applicable law (72 hours) about any personal data breaches.
- Data Protection Authorities: Subject to GDPR, you also have the right to (i) restrict our use of Personal Data and (ii) lodge a complaint with your local data protection authority about any of our activities that you deem are not compliant with GDPR.
Please keep in mind that in case of a vague access or any other request in exercise of the mentioned rights we may engage the individual in a dialogue so as to better understand the motivation for the request and to locate responsive information. In case this is impossible, we reserve the right to refuse granting your request.
Following the provisions of GDPR we might also require you to prove your identity (for example, by requesting an ID or other proof) in order for you to invoke the mentioned rights. This is made to ensure that no right of third parties are violated by your request, and the mentioned rights are exercised by an actual Personal Data subject or an authorized person.
Please also note that we will grant any request you might have within 30 days after receiving it. However, if VOIR cannot identify you, you may be requested to provide additional information necessary to confirm your identity.
5. Sharing your Personal Data
We will not rent or sell your Personal Data to third parties outside VOIR without your consent, except as Parties with whom we may share your information in accordance with this Policy.
Information Collected by Providers:
For the purposes of attribution and tracking the performance of the App (usage statistics) we may engage advertising and analytics third party providers (hereinafter – Providers), currently the following Providers are being engaged:
The lists of Service Providers may be amended from time to time, please refer to this Privacy Policy to obtain up-to-date information.
All Providers are either EU-based or compliant with the GDPR (for example, EU-US Privacy Shield Framework that ensures that the European data protection requirement is met).
The Providers may collect the following personal information about users of the Devices: IP address, device ID, advertising IDs and location data. Such information shall be collected directly by Providers and will not be shared with us. The Providers may combine such information with other personal information they have in their procession and may be used by them for targeted advertising, i.e. for showing the most relevant ads to you across Internet network.
If you do not wish your data to be processed for receiving a personalized advertising and analytical purposes you may send your request via support@voir.me.
Special Circumstances/ Responding to legal requests and preventing harm:
We will not share any of your Personal Data to any third party except as otherwise stated in this Privacy Policy and in the following circumstances: (i) in response to subpoenas, court orders or legal processes, to the extent permitted and as restricted by law (including to meet national security or law enforcement requirements); (ii) when disclosure is required to maintain the security and integrity of the App, or to protect any user's security or the security of other persons, consistent with applicable laws; (iii) when disclosure is directed or consented to by the user who has input the Personal Data; (iv) in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, your information will, in most instances, be part of the assets transferred.
Information Shared by User:
Any information (including Personal Data) you share in any online community area or online discussion is by design open to the public and is not private. You should think carefully before posting any Personal Data in any public forum. What you post can be seen, disclosed to, or collected by third parties and may be used by others in ways we cannot control or predict, including to contact you for unauthorized purposes. As with any public forum on any site, the information you post may also show up in third-party search engines. If you mistakenly post Personal Data in our community areas and would like it removed, you can send us an email as listed below to request that we remove it. In some cases, we may not be able to remove your Personal Data, e.g. for technical reasons.
6. Retention of your Personal Data
We will retain your Personal Data you provide us with for as long as it serves purposes for which you provided it to us. At any time, you can instruct us to remove it by emailing us at support@voir.me.
You should be aware that we may retain certain Personal Data and other information after your account has been terminated in an aggregated, anonymized form. We reserve the right to use your information in any aggregated data collection after you have terminated your account, however we will ensure that the use of such information will not identify you personally. We will also retain your Personal Data as necessary to comply with legal obligations, resolve disputes and enforce our agreements.
7. Data Security
We take all reasonable and appropriate measures to protect all collected Personal Data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data that we process and risks associated with special categories of Personal Data we collect (information about health). Among others, we utilize the following information security measures to protect your Personal Data:
a. Pseudonymization and tokenization of certain categories of your Personal Data;
b. Encryption of your Personal Data in transit and in rest;
c. Systematic vulnerability scanning and penetration testing;
d. Protection of data integrity;
e. Organizational and legal measures. For example, our employees and/or partners and/or service providers have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of the App.
We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable and appropriate steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.
8. International data transfers
The Company is based in the United States and the information we collect is governed by U.S. law. Please be advised that U.S. law and laws of other countries may not offer the same protections as the law of your jurisdiction.
In addition, you agree that information collected through the App may be stored and processed in Netherlands, Luxembourg, USA, where the Company rents servers, or in any other country in which the Company or its affiliates, subsidiaries or Providers maintain facilities, and by using the App, you consent to any such transfer of information outside of your country.
9. Children's Privacy
General age limitation including EU residents: VOIR does not knowingly collect or solicit any information from anyone under the age of 16. The App and Services and its content are not directed at children under the age of 16. In the event that we learn that we have collected personal information from a child under age 16 we will delete that information as quickly as possible.
10. Other websites and services
We are not responsible for the practices employed by any websites or services linked to or from the App or our Services, including the information or content contained within them. Please understand that this Privacy Policy applies only to information and Personal Data we collect from you. Where we have linked to a third-party website or service, you should read the privacy policy stated on that third-party website or service (for example, privacy policy of online stores linked from the App).
11. Complaints and Dispute Resolution
In compliance with the Principles, we commit to resolve complaints about our collection or use of your personal information. Any inquiries or complaints regarding our Privacy Policy please contact us at support@voir.me or mailing address at:
VOIR INC.
16192 Coastal Highway
Lewes, Delaware
19958 United States
Please also read (click on the link below) Section 12 of our Terms & Conditions for more information in relation to Dispute Resolution and Binding Arbitration (
https://voir.me/terms.html).
12. Arbitration
You may also be able to invoke binding arbitration for unresolved complaints but prior to initiating such arbitration, a resident of a European country participating in the Privacy Policy must first: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from our DPOEU (please see relevant information in Section 12 below); and (3) contact the relevant European Data Protection Authority and afford the Department of Commerce time to attempt to resolve the issue. If such a resident invokes binding arbitration, each party shall be responsible for its own attorney's fees. Please be advised that, pursuant to the Privacy Policy, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Policy Principles with respect to the resident. The arbitration option may not be invoked if the individual's same claimed violation of the Principles (1) has previously been subject to binding arbitration; (2) was the subject of a final judgment entered in a court action to which the individual was a party; or (3) was previously settled by the parties.
13. Data Protection Officer
If you are the resident of the EU and you wish to exercise your rights under Section 4 of the Privacy Policy, or you have any questions about this Privacy Policy or our privacy practices, you can contact our EU Representative through the email panos@dpoeu.eu or mailing address at:
DPOEU LTD
Krinou 3, Oval, Office 902,
Agios Athanasios, 4103
Limassol, Cyprus
Telephone No.: 00357 25 252027
BY USING THIS WEBSITE AND/OR SERVICES, YOU AGREE THAT YOU CONSENT TO THIS PRIVACY POLICY AND TERMS & CONDITIONS AND TO ANY CHANGES HERETO IN THE FUTURE. YOU AGREE THAT VOIR INC MAY AMEND THIS PRIVACY POLICY AT ANY TIME WITHOUT ANY GIVEN NOTICE AT ITS DISCRETION.
Last Updated: 30/12/2019