PRIVACY POLICY

This Laurageller.com Privacy Policy ("Privacy Policy") governs your use of the Laurageller.com website (the "Website"), which is owned by AS Beauty LLC (collectively, “Laura Geller”, “we” or “our”). We know how visitors like you value your privacy, and we have created this Privacy Policy to ensure that you understand our policies and procedures, what personal information you must provide if you wish to use certain portions of our Website and, ultimately, just how we use such personal information. This Privacy Policy is a part of and is incorporated into our Laurageller.com Terms and Conditions of Use. By accessing or using our Website or by otherwise giving us your information (including by using any virtual try-on feature), you accept and agree to, without limitation or qualification, the terms of this Privacy Policy. If you do not agree to this Privacy Policy, you must not use our Website or give us any of your information.

This Privacy Policy was last updated on February, 21 2023. We may make changes to this Privacy Policy at any time. In the event of any important substantive change(s) to how we use your information, how we protect your information or with whom we share it, we will communicate any such changes by updating this policy.

1. Information Collected By Our Website: This Privacy Policy applies to information that we collect from or about our customers through the methods described in this Privacy Policy. We note that not all of the methods listed below may apply to you. We collect two different types of information from users of our Website: personal information described below; and non-personal information such as information about traffic patterns on our Website.
   
   
2. Personal Information: Personal Information includes any information that would allow us to identify you or contact you, such as your name, home or mailing address, geographic location, payment information, user name, passwords, security questions and answers, biometric data (such as your image and facial geometry if you use our virtual try-on feature, uploading an image to our geller gal community), date of birth, age, age range, gender, favorite hobbies, interests, product purchase history, browsing history or other identifying information (collectively, “Personal Information”). This could also include information you give us about someone else (i.e., if you choose to ship a product to a friend or relative). We collect Personal Information in connection with a number of different activities, including, but not limited to creating an account, product purchases, customer service inquiries, use our virtual try-on feature, contests and promotions and customer feedback. To access certain portions of our Website, we require you to register and select a user name and password. Some personal data is collected during the registration process. If you create an account with us, your payment information may be stored under your account profile. We may also ask for additional information, including personally identifiable and non-personally identifiable information. To review or edit this information go to the Account/Login page on laurageller.com.
   
   When you make a purchase on our Website, call our customer service hotline, e-mail us an inquiry or when you enter a contest or other promotion, we may ask you for certain Personal Information such as your name, address, e-mail address, phone number, personal interests, credit card number, billing information etc., in order to process your order, provide you with information, administer the contest, or send you promotional e-mails. Providing Personal Information in these instances is solely your choice; you do not need to provide such information, make purchases, or enter such contests to browse our Website.
   
   Your username, password and security questions and answers should always be kept confidential and should never be shared with anyone else. To change your password, go to the Customer Login section of our Website or contact Customer Service at info@laurageller.com. Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometric data or genetic characteristics, criminal background, or trade union membership) on or through our services or otherwise to us.
   
   We may also collect information that you voluntarily share with us about your experience using our products, i.e., through comments, suggestions, reviews, customer service surveys or e-mail correspondence. We may also collect content you generate and send to us by e-mail, through our Facebook page, Instagram site, Website or other means. Examples include, but are not limited to, photos, videos or testimonials.
   
   If you interact with us on social media or use features such as plugins, widgets, or other tools made available by social media platforms or networks (such as Facebook, Instagram, Twitter, Google, You Tube, and Pinterest) in connection with our Website, we may collect the following: (1) any information you shared with us, (2) any information that is part of your public profile any information that the social media platform shares with us. This could include (but is not limited to) basic account information for the third -party site, user ID, geographic location (city, state, country), profile picture and list of connections/friends and/or any other information that you allow the third -party site to share with us. For further information concerning what information could be shared with us, please visit the website of such third party (e.g., Facebook, Instagram, Twitter, Google, YouTube, or Pinterest).
   
   We may collect information from you through one of our inbound text messaging programs. For example, periodically we may allow customers to send us inbound text messages using a short code that we create or advertise in connection with promotions or special offers. These programs may be advertised through our Website or corresponding application. If you choose to participate in one of these programs, data about your physical geo-location may be obtained and used for marketing purposes. This policy will only apply if our text messaging program indicates it applies or if it refers you to our Website to review the privacy provisions related to text messages.
   
   On occasion, we may collect information about you from other sources. For example, we may hire a third party data aggregator to provide us with further information about our customers, including from your profile or posting on third party social networking sites. We may also receive additional information by acquiring new companies or from other methods not inconsistent with this Privacy Policy.
   
   When you visit our Website, open or click e-mails we send you or interact with our advertisements, we or the third parties we work with automatically collect certain information using technologies such as cookies, web beacons, clear GIF, pixels, internet tags, web server logs, and other data collection tools. For more information, see section 6 below.
   
   In some cases we record customer service calls for quality assurance.
   
   In order to use our cloud-based virtual try-on feature for any of our products, you must consent to, among other things, how our service provider collects, possesses, processes, stores, shares and deletes your image and related biometric data (such as an analysis of your face to detect certain key facial landmarks), as described in our Virtual Try-On Information Notice. This data will only be stored temporarily while you are using the virtual try-on feature and will be permanently deleted when your use of the virtual try-on feature ends.
   
   We note that we strive to limit the amount of Personal Information we collect and store to that only necessary to deliver the relevant goods and services.
   
   
3. How We Use Your Personal Information: We use the information collected on our Website for a variety of purposes, including, but not limited to, running the Website and contacting users, fulfilling orders, account maintenance, customer service, product recommendations and improvements, contests and promotions, communications, Website personalization, third party on-line advertising, Website security and/or internal research, to detect, investigate, prevent or to take action regarding malicious, deceptive, fraudulent or illegal activity, including fraudulent transactions, attempts to violate our policies, procedures, terms and conditions, security incidents, and harms to the rights, property, or safety of Laura Geller and our users, customers, employees or others. In addition, we use Personal Information to comply with our legal or regulatory obligations, to exercise our rights, and to assert or defend against a legal claim.
   
   Our Website may also make available to other registered users information provided by you during registration, such as your screen name. We may use your information to communicate back to you, to update you on products, services and benefits, to personalize our Website for you, to personalize our advertising, marketing, communications, and promotional offers, to contact you for market research or to provide you with marketing information, newsletters, or other information we think would be of particular interest. In addition, if you make a purchase on our Website, we may send you order and shipping confirmation emails. We will always give you the opportunity to opt out of receiving such materials.
   
   When you use our cloud-based virtual try-on feature your biometric information will only be used for purposes of providing the virtual try-on feature. We and our service provider will not sell, lease trade or otherwise profit from your biometric data obtained when you use our virtual try-on feature.
   
   You can remove your e-mail address from our e-mail list at any time by following the procedures set forth in the “Opt Out Procedures” section below or by clicking on the "unsubscribe" link in every Laura Geller e-mail.
   
   Typically, we retain your Personal Information for the period necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law. Please note that in many situations we must retain all, or a portion, of your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, to protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes.
   
   Information obtained through our Website may be intermingled with and used in conjunction with information obtained through sources other than our Website, including both offline and online sources.
   
   
4. Discussions and Community Tools: Our Website may make product reviews, chat rooms, forums, bulletin boards, news groups and other community tools available to registered users and/or visitors. Please remember that any information that is disclosed in these areas becomes public information for other users to view and for Laura Geller to use. Please do not disclose any personally identifiable information in these publicly accessible areas of our Website. Please be considerate and respectful of others while using any chat rooms, forums or message boards to share your opinion.
   
   
5. Non-Personal Data: In some cases, we may collect non-personal information. Examples of this type of information include the type of internet browser you are using and version, the type of computer operating system application software, and peripherals you are using, the domain name of the website from which you linked to our Site, the IP address and the website usage (including, but not limited to, the links you click on and the pages you review). We use your information on an aggregated basis to do such things as operate and enhance our Website. This information is collected by using web beacons and cookies and may be collected from computers, tablets, smartphones and other devices, as well as by third party vendors such as Google Analytics. Website usage may be associated with your account or personal contact information. To learn more about Google Analytics, please see the information provided by Google.
   
   
6. Cookies and Similar Tracking Technologies: Certain features on our Website utilize cookie technology. A cookie is a small data file that certain websites write to your hard drive when you visit them. A cookie file can contain various types of information, including a user ID that the site uses to track the pages you've visited. We and our third-party partners use cookies, web beacons, clear GIF, pixels, internet tags, and other similar tracking technologies (collectively, “tracking technologies”) to gather information when you interact with our Website, texts and e-mail communications. Some tracking technologies help us maintain the security of our websites and your account, prevent crashes, fix bugs, save your preferences, and assist with basic website functions. We also permit third parties to use tracking technologies on our Website for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests or to send abandoned shopping cart reminders. The third parties use their technology to provide advertising about products and services tailored to your interests which may appear on our Website or on other websites. We may use cookies to enhance your experience on our Website, personalize your experience, to determine user traffic patterns and for other purposes.
   
   To the extent these tracking technologies are deemed to be a “sale” or “sharing” under California or any other state law, you can opt-out of these tracking technologies by submitting a request to us by e-mail at info@laurageller.com.
   
   Most browsers are initially set up to accept cookies; however, you can reset your browser to refuse all cookies or indicate when a cookie is being sent or you can flush your browser of cookies from time to time. (Note: you may need to consult the help area of your browser application for instructions.) If you choose to opt-out of the tracking technologies, disable your cookies setting or refuse to accept a cookie, you may not be able to access all areas of our Website. To learn more about cookies and how they work, see www.allaboutcookies.org.
   
   
7. Opt Out Procedures: You have the option to opt out of receiving information from Laura Geller and our Website. This opt out messaging will appear at the bottom of every email that is sent out. If you no longer wish to take advantage of our Website or receive any form of direct contact from Laura Geller or our Website, whether it is email, discounts, newsletters, or other promotional offers or materials, please contact us by e-mail at info@laurageller.com.
   
   
8. Reviewing or Changing Your Information: In order to ensure that the information we maintain is accurate, Laura Geller gives users the option to change or modify their information previously provided during registration. If you would like to change your information currently in our database please log in and click the "My Account" link on our Website.
   
   
9. Sharing of Your Information: Laura Geller may share your Personal Information: (i) with third parties who are under obligations of confidentiality with Laura Geller or with Laura Geller’s affiliates, subsidiaries or agents, (ii) if Laura Geller is required by law to do so, (iii) in the event of a transfer of ownership of Laura Geller, merger, sale, corporate restructuring, bankruptcy or other similar transaction, or (iv) as otherwise set forth in this Privacy Policy. The following describes some of the ways that your Personal Information may be disclosed to third parties:
   
   We may share Personal Information provided with one of our AS Beauty LLC brands (Julep, Mally, CoverFX).
   
   We may employ other third parties to perform services or functions on our behalf in order to improve our Website, merchandising, marketing and promotional efforts, communications or other services. We use third party tools and tracking technologies to record or collect information about users’ Website usage and activity, and information users provide via the Website (e.g., through the live chat and other features) in order to track and analyze customer data, determine the popularity of certain Website content and Laura Geller products, understand Website users’ online activity, enhance Website operations, deliver targeted advertising and content. This information is either recorded or accessed in real time by the unaffiliated third-party companies we engage to provide services on our behalf and is stored by these third parties for our use only.
   
   Those third parties may include authorized contractors, consultants and other companies working with us (collectively, "agents"). They only have access to Personal Information needed to perform their functions, and they may not share any Personal Information with others or use it for any other purpose than providing or improving Laura Geller’s services and offerings. In particular, if you interact with our virtual try-on experience, your biometric data will be obtained and processed by Laura Geller’s service provider(s) who help provide this cloud-based service.
   
   We may allow third party ad networks to collect and use your information (other than biometric data) to show you ads that are targeted to reach people (or people similar to people) who have visited our Website or provided us with Personal Information through other means (“Matched Ads”). This includes Laura Geller’s ads on other sites or our Website. In order to do this, we upload a customer list to the third party ad network or incorporate a pixel from the third party ad network on the Website, and the third party ad network matches common factors between our data and their data. At times, these ads may persuade you to come back and revisit the Website for new offers. This type of advertising generally includes an ad network that collects and tracks certain technical information (i.e., your IP address) and Website usage information (i.e., browsing history) on our Website and other Internet sites. To opt out of receiving Matched Ads, please go to https://www.networkadvertising.org/managing/opt_out.asp. We are not responsible for the third party ad network’s failure to comply with your opt-out requests.
   
   We may also have a need to transfer our customer information (including Personal Information), regardless of where you live, outside of the United States in which we or our agents have offices or facilities. By using the Website or otherwise doing business with us, you are agreeing to allow us to transfer your Personal Information outside of your home country and to process it inside the United States or elsewhere for the purposes stated in this Privacy Policy.
   
   This Privacy Policy applies only to Laura Geller’s Website and does not address the practices of third parties who may collect your Personal Information (other than our third party service provider(s) while they help provide our cloud-based virtual try-on experience). You may visit other websites, through links on our Website, which may collect, use and share your Personal Information in accordance with their own privacy policies. The information practices of those linked websites are not covered by this Privacy Policy, and we encourage you to be very cautious before you disclose your Personal Information to others.
   
   Laura Geller may be obligated to cooperate with various law enforcement inquiries. Laura Geller reserves the right to disclose or transfer Personal Information and non-Personal Information about you and your activities on our Website in order to comply with a legal requirement or request from law enforcement or other government officials, administrative agencies or third parties as we, in our sole discretion, determine necessary or appropriate for the administration of justice, or in connection with an investigation of fraud, intellectual property infringements or violations of any other law, rule or regulation, our Laura Geller.com Terms and Conditions of Use or other rules or policies of our Website, the rights of third parties, or an investigation of any other activity that may expose us or you to legal liability, or to investigate any suspected conduct which Laura Geller in its sole discretion deems improper.
   
   
10. Security: Providing a secure site is essential for your peace of mind and trust in Laura Geller. We maintain reasonable and appropriate physical, electronic and procedural safeguards designed to help protect your personal information. Specifically, we have installed encryption software conforming to the Secure Socket Layers (SSL) protocol to safeguard all of the information you send to us. All information is stored on our servers in a secure location. It is important for you to protect against unauthorized access to your password and to your computer. If your password is compromised, please notify Customer Service at once.
    
    
11. Protection for Children: Our Website is not intended for or directed to users under the age of 18. Furthermore, we have no intention of collecting Personal Information from children (i.e., individuals under the age of 16). Where appropriate, we take reasonable measures to inform children not to submit such information to our Website or in response to advertisements. If we become aware that a child under the age of 16 has provided Personal Information to us, we will delete the information from our records.
    
    
12. Privacy Precaution Warning: Please note that no data transmission over the Internet is 100% secure. As a result, we cannot guarantee the security of the information that you transmit via our online services. However, you can play a role in keeping your Personal Information safe. For example, you should choose an account password that is unique, difficult to guess and confidential. If you use a shared computer, never choose to have the computer save or remember your password and make sure to log out when you are finished using the Website.
    
    
13. Your Consent: By using our Website and providing your Personal Information to us, you also authorize the export of your Personal Information to the USA, as well as its storage and use as specified herein. Our headquarters is located in the state of New York, in the USA at 111 West 33rd Street, 16th Floor, New York, New York 10120. This Privacy Policy and our legal obligations are subject to the laws of New York and the USA, regardless of the location of any user. Any claims or complaints must be filed in the USA in the New York.
    
    
14. Third Party Sites/Features: Our Website may provide links to or features from other third party sites that we do not own or control. If you click on these links or use the features, you do so at your own risk. We are not responsible for the content or practices of any third party site or feature.
    
    
15. Contact Us: You can contact us at the following:
            111 West 33rd Street, 16th Floor, New York, New York 10120
              E-mail: info@laurageller.com.
    
    
16. Notice To Nevada Residents: Pursuant to Nevada law, you have the right to opt-out of the sale of certain covered personally identifiable information we have collected about you through our Website and online services, as those terms are defined under applicable Nevada law. If you are a Nevada resident and would like to opt-out of the sale of your covered information, please submit your request to info@laurageller.com. Your request must include your full name and zip code. Please contact us from the email address you have used to interact with us, or else provide us with that email address in your Nevada Opt-Out request email. We may contact you via such email address us as needed regarding this request. If you previously provided a phone number to us, including it in your Nevada Opt-Out request email, will assist us in identifying you and processing your request. You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request. We will respond to your request within sixty (60) days either confirming that your request has been processed or indicating that we need an additional thirty (30) days to complete the request.
    
    
17. California Privacy Rights: If you are a resident of California, the following sections are intended to provide certain information to you as required by the California law. These sections apply to personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household such as your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Personal information does not include publicly-available information and certain other information that is regulated by other applicable laws.
    
    You have the Right to Know and to request that we disclose certain information to you about our collection of your personal information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:
    
    - The categories of personal information we have collected about you
    - The categories of sources from which we have collected your personal information
    - Our business or commercial purpose(s) for collecting your personal information
    - The categories of third parties with whom we have shared your personal information
    - The specific pieces of personal information we have collected about you
    
    We do not sell any Personal Information to third parties.
    
    You have the right at any time to request that we delete your Personal Information. However, in some cases we may not be able to delete all or some of your Personal Information as required or permitted by applicable laws. Or we may need to delay a deletion, for instance, to process transactions you authorize such as a purchase of our products.
    
    We do not sell, rent, or otherwise share your data to or with any third-party for a business or commercial purpose under any circumstances. However, we are required to let you know that you have the right to opt-out of the sale of your Personal Information if we ever notify you that we engage in such activity.
    
    We will not discriminate against you for exercising your rights under California privacy laws.
    
    To submit a request to exercise any of your rights provided in this notice, please email info@laurageller.com. We will evaluate the request and take action where required to do so. Depending on the nature of your request, we may have to verify your identity when you contact us. We do this by asking you to provide us with certain pieces of personal information which we will match with information we have in our possession to verify your identity.
    
    We endeavor to respond to your request as soon as we can. If we are not able to respond to your request within forty-five (45) days, we will let you know that we may require additional time (up to ninety (90) total days).
    
    You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent, we require that your authorized agent provides written proof that he/she is authorized to act on your behalf, and we may also require your authorized agent to verify his or her own identity. To appoint an authorized agent, please contact us at info@laurageller.com. We are not able to respond to more than one “Right to Know” request from a consumer in any 12-month period.
    
    Depending on your specific personal interaction with us or by using this Website, we may have collected the following categories of personal information from consumers in the last twelve (12) months: identifiers (e.g. real name, address, email address); characteristics of protected classification under California or Federal law; commercial information (e.g. products purchased, obtained, or considered, or other purchasing or consuming histories); internet or other electronic network activity (e.g. browsing history, search history, or a consumer’s interaction with a website); geolocation data; audio, visual, and similar information; professional or employment related information; inferences drawn from any of the information above to create a profile about a consumer (reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and attitudes); biometric information; or any other category of information consistent with this Privacy Policy.
    
    Our sources for this information include: information we receive directly from you; information we may have licensed data from third-party data providers; information received from our third-party advertising partners; information received through third party social networks (such as Facebook); or any other sources consistent with this Privacy Policy.
    
    Our business purposes for collecting this information include: to fulfill our contractual obligations with you; to improve our website and our services; to send you updates about our company; to send targeted marketing campaigns; or any other purpose consistent with this Privacy Policy.
    
    As discussed above, we do not sell, rent, or otherwise share your data to any third-party for a business or commercial purpose under any circumstances. However, we may share your data with third-party vendors or service providers engaged by us to help provide the services permitted by the Privacy Policy. Each third-party vendor or service provider is obligated to only use your personal information to provide the contracted services and for no other purpose. Further, each third-party vendor or service provider must contractually agree to robust privacy and security obligation prior to engagement, including the secure deletion of your data upon the termination of our agreement
    
    
18. California “Do Not Track” Notice: We do not currently recognize and process “do not track” signals from different web browsers. For more information on “do not track” please visit https://allaboutdnt.com/.
    
    
19. California Shine the Light: California law permits California residents to request notice of how their personal information is shared with third parties for direct marketing purposes. If you are a California resident and would like a copy of this notice, please contact us at info@laurageller.com.
    
    
20. Notice of Financial Incentive: We offer customers a loyalty program (the Geller Gal Rewards) that provides certain perks, such as rewards and exclusive offers. We may also provide other programs such as sweepstakes, contest, or other similar promotional campaigns (collectively, the “Programs”). When you sign up for one of these Programs, we typically ask you to provide your name and contact information (such as an e-mail address and/or telephone number). Because our Programs involve the collection of personal data, they may be interpreted as a “financial incentive” program under California or other state laws. The value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the applicable Program, less the expense related to offering those products, services, and benefits to Program participants. You may withdraw from participating in a Program at any time by contacting us pursuant to Section 15 above.