Privacy

Cuebey, LLC Privacy Policy

This privacy notice applies solely to information collected by the Curlpattern mobile app (or ‘service) and all related apps. It will notify you of the following:

1. What personally identifiable information is collected from you through the app, how it is used and with whom it may be shared.
2. What choices are available to you regarding the use of your data.
3. The security procedures in place to protect the misuse of your information.
4. How you can correct any inaccuracies in the information.

Information Collection, Use, and Sharing

1. Information We Collect
Personal information you disclose to us
‍While using the app, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Information”). Personal Information may include, but is not limited to your name, email address, other contact and demographic information, and password and security information.

We will use your information to respond to you, regarding the reason you contacted us. We will not share your information with any third party outside of our organization or our third-party service providers and partners.

Unless you ask us not to, we may contact you via email in the future to tell you about specials, new products or services, or changes to this privacy policy.

Information we automatically collect

We collect information about how you access and interact with the app  such as, but not limited to, device type, IP address, operating system, device id and other usage and diagnostic data.  This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. For example, we may use information we collect to better understand app usage and to optimize our users’ experience.

Push Notifications

Additionally, we may request to send you push notifications regarding your Account or the App. If you wish to change our access or permissions or opt-out from receiving push-notifications, you may turn such features off in your device’s settings.     

User Uploaded Content

Curlpattern collects user uploaded hair images to generate a hair texture profile. We then filter your results by that texture profile to display content from the web and social media that is most relevant for you and your hair type. We do not link the image to your user id, account or device. We do not share your uploaded images with third parties. We temporarily store uploaded hair images on our app database. We then delete all uploaded hair images from our systems and databases within 3 days. The sole purpose of the uploaded hair images is to run them, anonymously, through our machine learning model to detect the hair texture profile.

2. How we use your information

Provide, maintain, and improve the Service

We may use your information to:

• facilitate the creation and securing of your account
• Provide customer service
• Send you confirmations, updates, security alerts, and other messages
• Detect and prevent fraud
• Perform analytics and connect research to troubleshoot and protect against errors

Sharing your information

If you use our app, you are authorizing us to share information:

• that you direct us to disclose to others
• with our third-party vendors, business partners, vendors and consultants who provide services on our behalf or who help us to provide services.
• As reasonably necessary or appropriate to protect the rights, property or safety of us, our users, our employees copyright owners, third parties or the public, including without limitation to protect us, our users or the public from fraudulent, abusive, inappropriate or unlawful use of our service
• In connection with or during negotiations of any merger, sale of company assets, financing or acquisition, or in any other situation where information may be disclosed or transferred as one of our business assets

Nothing herein restricts the sharing of aggregated or anonymized information, which may be shared with third parties without your consent. This Policy in no way restricts or limits our collection and use of aggregate or de-identified information

Links to third-party sites and services
‍The Service may contain links to other websites. We are not responsible for the practices employed by websites or services linked to or from the app, nor the information or content provided to or contained therein. Please remember that when you use a link to go from the Service to another website, this Policy does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our app, are subject to that third party’s own rules and policies. Please read those rules and policies before proceeding.

Your Access to and Control Over Information
You may opt out of any future contacts from us at any time. You can do the following at any time by contacting us via the email address or phone number given on our app:

• See what data we have about you, if any.
• Change/correct any data we have about you.
• Have us delete any data we have about you.
• Express any concern you have about our use of your data.

3. How We Protect Your Information
We take measures designed to protect your information in an effort to prevent loss, misuse, unauthorized access, disclosure, alteration, and destruction. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. To protect the confidentiality of information maintained in your Account, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of the Service by any person using your password. Please advise us immediately if you believe your password has been misused. We will only retain your Personal Information as long as reasonably required for you to use the Service and/or to provide you with the Service unless a longer retention period is required or permitted by law (for example, for regulatory purposes).
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4. International Data Transfers
Personal Information we collect from you may be stored and processed in any country where we have operations or where we engage service providers. We may transfer your Personal Information to recipients in countries other than the country in which the Personal Information was originally collected, including to the United States, where data protection laws may differ from the laws of the country where you are a resident. By providing us with your data you acknowledge and agree that your Personal Information may be processed for the purposes identified in this Policy. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
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5. California Privacy Rights
Under California’s “Shine the Light” law, California residents have the right to request and obtain a list of the third parties, if any, to which personal information (as defined by California law) has been disclosed for their direct marketing purposes during the immediately prior calendar year. If you are a California resident and want a copy of this information, please submit a written request to us at the address provided in the Contact section below. In your request, please specify that you are requesting a “Your California Privacy Rights Notice.” Please allow 30 days for a response.

Registration
In order to use certain portions of this app, a user must first complete the registration form. During registration a user is required to give certain information (such as name and email address). This information is used to contact you about the products/services on our site in which you have expressed interest. At your option, you may also provide demographic information (such as gender or age) about yourself, but it is not required.

7. Opting Out
You may “opt out” of receiving marketing or promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your Account or our ongoing business relations.
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8. Changes and Updates to the Policy
We reserve the right to change the provisions of this Policy at any time. Please revisit this page periodically to stay aware of any changes. If we modify this Policy, we will make it available through the Service and indicate the date of the latest revision. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood, and agreed to the current version of this Policy.

Retention

Cuebey will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active (i.e., for the lifetime of your Cuebey member account), or as needed to provide the Services to you. If you no longer want Cuebey to use your information to provide the Services to you, you may close your account. Cuebey will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. In addition, Cuebey vendors/sellers may also be required to retain and use your information in order to comply with their own legal obligations. Please note that closing your account may not free up your email address, username, or shop name (if any) for reuse on a new account. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for site safety and security, to improve site functionality, or we are legally obligated to retain them for longer time periods.

Legal Bases

When you access or use the Services, we collect, use, share, and otherwise process your personal information for the purposes described in this policy. We rely on a number of legal bases to use your information in these ways. These legal bases include where:

• Necessary to perform the contractual obligations in our Terms of Use and in order to provide the Services to you;
• You have consented to the processing, which you can revoke at any time;
• Necessary to comply with a legal obligation, a court order, or to exercise or defend any impending or asserted legal claims;
• Necessary for the purposes of our or a third party’s legitimate interests, such as those of visitors, members, or partners (described in more detail below);
• You have expressly made the information public;
• Necessary in the public interest, such as to prevent crime; and
• Occasionally necessary to protect your vital interests or those of others (in rare cases where we may need to share information to prevent loss of life or personal injury).

Our Legitimate Interests

Where we process your information on the basis of legitimate interests, we do so as follows:

Providing and Improving our Services: We use your information to improve and customize our Services, including sharing your information for such purposes, and we do so as it is necessary to pursue our legitimate interests of improving our Services for our users. This is also necessary to enable us to pursue our legitimate interests in understanding how our Services are being used, and to explore and unlock ways to develop and grow our business. It is also necessary to allow us to pursue our legitimate interests in improving our Services, efficiency, interest in Services for users, and obtaining insights into usage patterns of our Services. As a core part of our Services, we have a legitimate interest in customizing your on-site experience to help you search for and discover relevant items and recommended purchases, including using this information to help sellers find the best ways to market and sell their products on Cuebey.

Keeping our Services Safe and Secure: We use your information for safety and security purposes, which can include sharing your information for such purposes, and we do so because it is necessary to pursue our legitimate interests or those of a third party in ensuring the security of our Services, preventing harm to individuals or property, or crime, enforcing or defending legal rights, or preventing damage to Cuebey’s systems, or those of our users or our partners. This includes enhancing protection of our community against spam, harassment, intellectual property infringement, crime, and security risks of all kinds. We use your information to provide and improve the Services, for billing and payments, for identification and authentication, and for general research and aggregate reporting.

Legal and Safety: Cuebey may also retain, preserve, or release your personal information to a third party in the following limited circumstances: in response to lawful requests by public authorities, including to meet legitimate national security or law enforcement requirements; to protect, establish, or exercise our legal rights or defend against impending or asserted legal claims, including to collect a debt, or a material violation of our policies (including our Intellectual Property Policy); to comply with a subpoena, court order, legal process, or other legal requirement; or when we believe in good faith that such disclosure is reasonably necessary to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our rights or property, or violations of Cuebey’s User agreement. In these cases, our use of your information may be necessary for the purposes of our or a third party’s legitimate interest in keeping our Services secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage. Such use may also be necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims. It may also be necessary in the public interest (such as to prevent crime) or to protect vital interests (in rare cases where we may need to share information to prevent loss of life or personal injury).

If Cuebey receives a lawful, verified request for a member’s records or information in one of the limited circumstances described in the previous paragraph, Cuebey may disclose personal information, which may include, but may not be limited to, a member’s name, address, phone number, email address, and company name.

Service Providers: Cuebey also needs to engage third-party companies and individuals (such as research companies, and analytics and security providers) to help us operate, provide, and market the Services. These third parties have only limited access to your information, may use your information only to perform these tasks on our behalf, and are obligated to Cuebey not to disclose or use your information for other purposes. Our engagement of service providers is often necessary for us to provide the Services to you, particularly where such companies play important roles like helping us keep our Service operating and secure. In some other cases, these service providers aren’t strictly necessary for us to provide the Services, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our Services better.

Privacy Policy Changes

We may amend or update this policy from time to time. If we believe that the changes are material, we’ll let you know by doing one (or more) of the following: (i) posting the changes on or through the Services, (ii) sending you an email or message about the changes, or (iii) posting an update in the version notes on the Apps’ platform. We encourage you to check back regularly and review any updates.