REFLECT BEAUTY PRIVACY POLICY

 

Last Updated:  September 26, 2019

 

The Reflect Beauty website was designed to protect the privacy of our users.  We believe that privacy is a right, and that you have a right to keep it private. Our goal is to be transparent about how we collect and use information about you, to keep such information secure, and to provide you with meaningful choices.  

 

 

WHAT THIS POLICY COVERS

 

Our Privacy Policy explains:

  • What information we collect and why we collect it.

 

  • How we use that information.

 

  • The choices we offer, including how to access and update information about you.

 

 

TABLE OF CONTENTS

 

What this policy covers:

 

ABOUT US

CROSS BORDER DATA TRANSFERS

TRANSPARENCY AND CHOICE

INFORMATION WE COLLECT

HOW WE COLLECT INFORMATION

HOW WE USE THE INFORMATION COLLECTED

SHARING THE INFORMATION COLLECTED

INFORMATION OUR VENDORS AND OTHER THIRD PARTIES COLLECT

LINKS

LEGAL BASIS FOR PROCESSING INFORMATION (EEA residents only)

EUROPEAN DATA SUBJECT RIGHTS

CLOSING YOUR ACCOUNT; DELETING INFORMATION

DO NOT TRACK

SECURITY

RETENTION OF INFORMATION

EMAIL OPT OUT

CHANGES TO THIS PRIVACY POLICY

CONTACT INFORMATION

 

 

BY USING THE SITE, YOU AGREE THAT YOU HAVE READ AND UNDERSTOOD, AND AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT UNDERSTAND, OR DO NOT AGREE TO BE BOUND BY THIS PRIVACY POLICY, YOU MUST IMMEDIATELY STOP USING THE SITE.

ABOUT US

 

Mirror Digital, Inc. (“we”, “our”, or “us”) is a Delaware corporation located in the United States of America that operates the Reflect Beauty website located at http://reflectbeauty.com(“Site”).  We provide premium, high impact advertising products and services and leading campaign management, helping advertisers target the growing multicultural market through our network of social media influencers, boutique digital publishers and bloggers using online advertising (“Service”).

 

The Site is a media platform created for us, by us, to be your mirror in the beauty, fashion, health, and wellness space.  We seek to drive awareness and achieve real, lasting beauty equity worldwide by celebrating the very best in beauty products catering to the diversity of pigments, textures, and tones that accurately reflect us, our inner and outer beauty, and our unique achievements to shine a light on the beauty of women of all colors around the world.    

 

Ads and sponsored content are displayed on the Site, as well as other websites and applications, each of which rely on advertising revenue to support the free content we consume every day.  Our goal is to make advertising and sponsored content more relevant and useful to our users by showing them ads that are based on their specific interests.  

 

To do this, when you visit the Site, we may collect some or all of the information described in this Privacy Policy.  We use that information, and other information described below, to help show you ads on the Site and other websites or applications that are more relevant and useful to you.

 

The Site is hosted in the United States, and is not directed to individuals under the age of sixteen (16).  We do not knowingly collect information from individuals under sixteen (16) years of age without prior parental consent or consistent with applicable law. 

 

CROSS BORDER DATA TRANSFERS

 

The Site may be available worldwide.  If you use the Site from outside of the United States of America, or are served an ad through the Site while located outside of the United States of America, data about you may be transferred to, stored and processed wherever we, our corporate affiliates, or the third parties with whom we may share information about you as described in this Privacy Policy, operate in connection with the Site.  You authorize us to use the information collected in connection with the Site as explained below, which may involve transferring and storing such information across and outside your country to a country (such as a country outside of the European Economic Area) that may provide a different level of protection for such information. 

TRANSPARENCY AND CHOICE

 

People have different privacy concerns.  We believe you should have tools to control information about you and manage your experience with us.  For example, consumers who are served ads through the Site may opt out of interest-based or targeted advertising at https://adssettings.google.com/authenticated?hl=en. Please note that if you opt out of receiving interest-based or targeted advertising, you will continue to see the same number of ads, but they will be generic in nature, and may not be as relevant or useful to you. 

 

You can also learn more about interest-based or targeted advertising and ad serving companies and opt-out capabilities at the Network Advertising Initiative Website, Digital Advertising Alliance Website, Digital Advertising Alliance of Canada,TrustArc, European Interactive Advertising Digital Alliance, and Your Online Choices.  Please note that these opt-outs operate by placing an opt-out cookie on your device that is unique to the browser and device you used to opt-out. They may not function properly if you configured your browser to reject certain cookies. If you change browsers or computers, or delete the cookies on your computer, you will need to opt-out again. You also may be able to set your browser to notify you when a cookie is being set and to block most cookies.  Your mobile device may give you the ability to opt-out of interest-based advertising (“Limit Ad Tracking” on iOS devices or “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices).

INFORMATION WE COLLECT

 

We collect information to provide a better user experience on the Site, and to assist our advertiser and publisher clients, which includes offering a premium digital advertising network, enabling the purchase of targeted advertising, measuring advertising performance, and providing related research.  

 

We may collect and combine information when you interact with the Site, including:

 

  • Information you give us. We collect the information that you voluntarily give us such as your name, email address, and phone number;

 

  • Information from your use of the Site. We collect information about how our users interact with the Site.  This information includes:

 

    • Device and browser information: such as the IP address, information about the device to which an ad was served such as an anonymous device identifier, device type, software version, browser used, and settings, and the URL of the page you are visiting;

 

    • Location information: such as information that allows us to periodically determine the location of a user who was served an ad through the Site.  For iOS consumers, you should be able to adjust the settings on your iOS device to prevent collection of location information by disabling the location services feature on your device.  For Android consumers, you should be able to adjust your settings on your Android device to prevent collection of location information by disabling Bluetooth and location service features on your device; and

 

    • Ad Data: such as data about the ads served through the Site, for example, how many times an ad has been served to you, where or on which page the ad was served, whether you clicked on or otherwise interacted with the ad, and attributing any actions or purchases to an ad.

 

We do not collect any “sensitive” or “special categories of personal data” as defined under European data protection laws.

HOW WE COLLECT INFORMATION

 

We use cookies and other standard web technologies to collect information automatically from your device, including:

 

  • Cookies: are data files that often include a unique identifier, and are placed on a consumer’s device or computer. We use cookies to deliver targeted content and/or advertising, and for Site analytics.  You can learn more about how to delete, decline, or control cookies at www.aboutcookies.org.  If you choose to delete or decline cookies, certain features of the Site may not function properly or not at all.

 

  • Device advertising identifiers: are standard device identifiers, for example the identifier for advertisers (“IDFA”) used on Apple’s iOS devices, the “Google Advertising ID” advertising identifier used on Android devices, or publisher provided identifiers (“PPID”).

 

  • Web beacon; tags; pixels: are blocks of code that can read and place cookies, recognize certain types of information on your device, and your browsing behavior, as well as support Site analytics; and

 

  • SDKs or Software Development Kits: are blocks of code similar to web beacons, tags, and pixels that are embedded into an application that allow us to analyze certain information relating to your install, activation, and use of applications.

HOW WE USE THE INFORMATION COLLECTED

 

We use the information collected to provide the Site and the Service.  For example, we use the information collected for the creation and purchase of targeted advertising campaigns.  Such information may be used by itself, aggregated, or combined with other information we collect or from a third party.  We may also use information collected to deliver you information and/or promotional materials about Reflect Beauty and/or to carry out other purposes that are disclosed to you, and to which you consent.

 

We may also use the information collected for the following purposes:

 

  • To improve the Site;

 

  • To deliver personalized ads so they are relevant and effective;

 

  • To limit or cap the ads served so that you don’t see the same ad too many times;

 

  • To sequence ads, making sure a series of ads are served in the correct order;

 

  • To provide support to our advertising clients;

 

  • To cross-device match, identifying all devices that are likely to be associated with a user so that ads can be personalized, capped and sequenced across those devices;

 

  • To measure and report on advertising campaign performance, such as whether a user clicked on an ad, went to the advertiser’s website after the ad was served, attributing actions or purchases to an ad, and/or transaction reporting and verification;

 

  • To manage your account with us;

 

  • To protect the safety and security of our users who are served ads through the Site, including acting in urgent circumstances;

 

  • To protect or defend the legal rights or property of Reflect Beauty, our users, and third parties, including business partners such as advertising-related companies, as well as our corporate affiliates, in connection with the Site;

 

  • To investigate, deter, and report against fraudulent, invalid, unauthorized, malicious, or illegal activity, and/or risk management; and

 

  • To comply with applicable law, rules, regulations, or legal process.

SHARING THE INFORMATION COLLECTED

 

We may share the information collected as follows:

 

  • Advertisers and Publishers: We may share information collected with our advertiser and publisher clients and third parties, including business partners such as advertising-related companies who are obligated to comply with applicable laws concerning usage of the information, as well as our corporate affiliates, in connection with the Site (such third parties and affiliates collectively, “Affiliates”).  In addition, our Affiliates may share this information with their own third-party business partners who may use the information either for themselves or on behalf of the applicable Affiliate, each only for the purposes set forth in the section above headed How We Collect Information.

 

  • Site providers: We may share information collected with our service providers to facilitate some aspects of the Site or perform functions on our behalf.  These service providers may use information about you solely for the purpose of providing these services to us or on our behalf;
  • Legal and other purposes: We may share information collected with law enforcement, regulatory authorities, courts with competent jurisdiction, emergency services, or other necessary third parties for legal, protection, security, and safety purposes; and

 

  • Business transfers: We may share information collected in connection with the sale or transfer of all or a part of our business or assets to a third party buyer.

INFORMATION OUR VENDORS AND OTHER THIRD PARTIES COLLECT

 

  • Analytics Site Providers

 

    • We may allow certain third party analytics service providers to collect the anonymous data received from cookies, web beacons, tags, pixels, and devices on our behalf, and to retain and use this data themselves. We may also share portions of our log file data, including IP addresses, with these service providers for analytics purposes.

 

    • These service providers offer information about their data collection practices, and in some cases, an opt-out, on their respective websites. To obtain a list of these service providers in order to request their privacy policy information and learn about the controls that may be available to you, please contact us using the details in the Contact Information section below. 

EUROPEAN DATA SUBJECT RIGHTS

 

If you are a resident of a country in the EEA, you have certain rights and protections under the law regarding the collection, processing, and use of information about you.   As set forth above, the information that we collect about you when you use the Site may include certain digital identifiers that are considered “personal data” under European law.  We primarily process and store this data in the United States of America either as necessary to further our legitimate interest and/or pursuant to your consent.  We transfer, process and store personal information outside of the EEA, to wherever we, our Affiliates, or the third parties with whom we may share information about you as described in this Privacy Policy, operate in connection with the Site.

 

As a resident of a country in the EEA, you have the right to:  (i) request access to and obtain a copy of the information we collect about you; (ii) request rectification or erasure of such information; (iii) restrict the processing of such information; and (iv) if applicable, data portability with respect to such information.  In certain circumstances, you may also have the right to object to the processing of such information.

 

If you would like to exercise any of these rights, please contact us using the details in the Contact Information section below.  Please note that because most of the information we collect and maintain about you can only identify a particular browser or device, and cannot identify you individually, you may need to provide us with additional information to enable us to identify the information we have about you and ensure that we accurately fulfill your request.  Although we use good faith efforts to respond to your request, we may not be able to provide and/or correct the requested information in all situations.  For example, we may not be able to provide the information requested if it imposes an undue burden or expense, requires us to release confidential commercial information, or requires the disclosure of information relating to another person.

 

Finally, as a resident of the EEA, you have the right to lodge a complaint about our processing of personal data with a European Data Protection Authority.  For contact details of your relevant local Data Protection Authority, please review the information located at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.  

CLOSING YOUR ACCOUNT; DELETING INFORMATION

 

If you established an account with us, our goal is to delete the Reflect Beauty account information requested within 30 days of receiving your written request.  If you close your Reflect Beauty account, we will use reasonable efforts to ensure that information about you in the account such as your name, email or billing information is no longer accessible or used by the Site.  However, as permitted by applicable law, we retain and may use information about you as necessary to comply with our legal and/or financial obligations, resolve disputes, enforce our agreements, and other legitimate purposes (including, for corporate governance, financial record keeping, document retention, and security purposes).  Please contact us using the details in the Contact Information section below to close your Reflect Beauty account or request changes or modification of the information you previously provided to us.  Closing your Reflect Beauty account does not affect ads you may receive on any of your devices.

DO NOT TRACK

 

Do Not Track (“DNT”) is a privacy preference that you can set in your browser that requests that websites and technology companies not collect certain browsing data. Currently, the standards regarding DNT and appropriate responses are not well defined. As such, Reflect Beauty does not currently honor DNT settings in your browser.

SECURITY

 

Reflect Beauty uses industry-standard physical, electronic, and procedural measures designed to safeguard the information in our possession against loss, theft and unauthorized use, disclosure, or modification. However, please note no transmission of information via the Internet or electronic storage solution can be guaranteed to be completely secure, although we take reasonable precautions to protect against security incidents. 

RETENTION OF INFORMATION   

 

We store information you provide to us (a) for as long as (i) needed to provide you the Site, or (ii) you have a commercial relationship with us, or (b) until you request that we delete your Reflect Beauty account.  We store the information collected about consumers who are served ads through the Site for 18 months before it is deleted, except that information collected regarding the ads served, including ad performance and attribution, are stored for 18 months before that data is anonymized and aggregated into summary reports.  

 

In some cases notwithstanding the above, we may keep certain information for longer periods of time as permitted by applicable law, including to comply with our legal and/or financial obligations, resolve disputes, enforce our agreements, and other legitimate purposes (including, for corporate governance, financial record keeping, document retention, and security purposes).

EMAIL OPT OUT

 

You may opt-out of receiving promotional communications from us, by clicking on the “unsubscribe” link in the emails you receive from us, or by contacting us using the details in the Contact Information section below to have your contact information removed from our promotional email list.

CHANGES TO THIS PRIVACY POLICY

 

From time-to-time, Reflect Beauty may modify this Privacy Policy to reflect industry initiatives, regulatory reasons, changes in the law, our information collection and use practices, or changes in the features of the Site or technology.  Therefore, it is important that you review this Privacy Policy regularly to ensure you are updated as to any changes.

 

If Reflect Beauty materially changes our practices regarding collection or use of personal information about you, such information will continue to be governed by the Privacy Policy under which it was collected, unless you have been provided notice of, and the opportunity to choose not to have such information about you used as described in the revised Privacy Policy before such changes take effect, which may require that you stop using the Site and deactivate your Reflect Beauty account, as outlined above.

CONTACT INFORMATION

 

If you have any questions or concerns about this Privacy Policy, please contact us at general@mirror-digital.com or at:

 

Residents outside of the European Economic Area:

 

Mirror Digital, Inc.

Attn: Privacy Officer

3535 Hayden Avenue, Suite 315

Culver City, CA 90232

 

European Economic Area residents:

 

Mirror Digital, Inc.

Attn: Data Protection Officer

3535 Hayden Avenue, Suite 315

Culver City, CA 90232

 

Important note: The data controller of information about European Economic area residents is Mirror Digital, Inc. at the above address.