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Privacy Policy

PRIVACY POLICY

Last updated May 01, 2025

This Privacy Notice for ShopAlura LLC ("we", "us", or "our") explains how and why we may access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

  • download and use our mobile application (Alura – Makeup For You) or any other application of ours that links to this Privacy Notice;
  • engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at alura@alura.co.

SUMMARY OF KEY POINTS

  • What personal information do we process? When you visit, use, or navigate our Services we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
  • Do we process any sensitive personal information? We process facial data only when you explicitly capture an image through our app for the purpose of makeup recommendations and virtual try-on features.
  • Do we collect any information from third parties? We do NOT collect information from third parties.
  • How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We also process your information for other purposes with your consent and only when we have a valid legal reason to do so.
  • When and with whom do we share personal information? We share information in specific situations and with specific third parties. Face data is never sold or shared with third-party advertisers.
  • How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100 % secure.
  • What are your rights? Depending on where you are located, applicable privacy law may mean you have certain rights regarding your personal information.
  • How do you exercise your rights? The easiest way is by visiting the privacy‑request portal (__________) or by contacting us. We will consider and act on any request in accordance with applicable data‑protection laws.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

5. DO WE OFFER ARTIFICIAL‑INTELLIGENCE‑BASED PRODUCTS?

6. HOW LONG DO WE KEEP YOUR INFORMATION?

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

8. WHAT ARE YOUR PRIVACY RIGHTS?

9. CONTROLS FOR DO‑NOT‑TRACK FEATURES

10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

11. DO WE MAKE UPDATES TO THIS NOTICE?

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

14. FACE DATA COLLECTION AND PROCESSING

1. WHAT INFORMATION DO WE COLLECT?

PERSONAL INFORMATION YOU DISCLOSE TO US

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, participate in activities on the Services, or otherwise contact us. The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. It may include:

  • names
  • email addresses
  • passwords
  • facial data (when you explicitly capture an image through our app)

Sensitive Information: We collect and process facial data only when you explicitly capture an image through our app. This includes the face image itself, facial landmarks and measurements (positions and shapes of facial features like eyes, nose, lips, jawline), and derived attributes (calculated data such as skin tone values and undertone classification). This data is collected solely to provide personalized makeup recommendations and virtual try-on features.

Payment Data: If you make purchases we collect data necessary to process your payment (e.g., payment‑instrument number and security code). All payment data is handled and stored by Apple (see https://www.apple.com/legal/privacy/en‑ww/).

Application Data: If you use our application(s) we may request access or permission to send you push‑notifications regarding your account or certain features. You may turn them off in your device settings.

Automatically Collected Information

In Short: Some information — such as your IP address and/or browser and device characteristics — is collected automatically when you visit our Services. This may include log and usage data, device data, and location data.

Google API

Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited‑Use requirements.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your information to provide, improve, and administer our Services; communicate with you; prevent fraud; and comply with law. We also process your information for other purposes with your consent. We rely on valid legal reasons ("legal bases") to process your personal information, depending on how you interact with our Services.

For facial data specifically, we process this information solely for the following purposes:

  • Personalization: To match makeup shades and product recommendations to your unique complexion
  • Virtual try-on rendering: To accurately apply and position cosmetic effects on your face
  • Search and recommendations: To improve product ranking and suggestions based on your interaction over time
  • Model training (anonymized only): Aggregated, de-identified data may be used to improve our shade-matching algorithms and system performance

We do NOT use face data for identity verification, advertising, government use, or health analysis.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share information with third parties in the following situations:

  • Service Providers
  • Business Transfers
  • Affiliates
  • Business Partners
  • Other Users (when you share public information or interact in community areas)

Face Data: We use Google Cloud Platform to securely store and process facial data. Google does not have access to user-identifiable information and does not use our data for its own purposes. We do NOT sell, share, or license face data to any third-party advertisers or unrelated entities.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: Yes, we may use cookies and other tracking technologies to collect and store your information for analytics, advertising, security, and essential site functionality.

5. DO WE OFFER ARTIFICIAL‑INTELLIGENCE‑BASED PRODUCTS?

Yes. When you use any AI‑powered feature, the inputs you provide and the outputs generated may be processed to operate, improve, and secure that feature in accordance with this Privacy Policy.

Our makeup recommendation and virtual try-on features use artificial intelligence to analyze facial characteristics and provide personalized recommendations. These features only process facial data when you explicitly capture and submit an image through our app.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

For facial data specifically:

  • Active accounts: Data is retained as long as you maintain an active account
  • Deleted accounts: All associated face data is permanently deleted from both active storage and backups within 30 days of deletion request

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, no system is 100 % secure.

Facial data is encrypted and stored in Google Cloud infrastructure within secure, access-controlled environments with strict security protocols in place.

8. WHAT ARE YOUR PRIVACY RIGHTS?

Depending on your location, you may have rights to access, rectify, delete, or restrict the processing of your personal information, among other rights.

For facial data, you have the right to:

  • Delete your facial data at any time through the app settings
  • Request a copy of your facial data
  • Opt out of the use of your anonymized facial data for model training

9. CONTROLS FOR DO‑NOT‑TRACK FEATURES

Most web browsers and some mobile operating systems include a Do‑Not‑Track ("DNT") feature. We do not currently respond to DNT signals.

10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Yes. Residents of certain US states (e.g., California, Virginia) are granted additional privacy rights under their respective state laws.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes. We will update this notice as necessary to stay compliant with relevant laws. The revised version will be indicated by an updated "Revised" date.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

Email: alura@alura.co

Postal Mail: ShopAlura LLC, 5792 Tiger Lane, Frisco TX 75035, United States

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You can submit a data‑subject request by visiting the privacy‑request portal (__________) or emailing alura@alura.co. We will verify and respond in accordance with applicable law.

14. FACE DATA COLLECTION AND PROCESSING

In Short: We collect facial data only when you explicitly capture an image through our app, and we use this data solely to provide personalized makeup recommendations and virtual try-on features.

What face data we collect:

  • Face image: A single, still-frame image captured by you through the app
  • Facial landmarks and measurements: Positions and shapes of facial features (e.g., eyes, nose, lips, jawline) derived from the image
  • Derived attributes: Calculated data such as skin tone values and undertone classification

How we use face data:

  • Personalization: To match makeup shades and product recommendations to your unique complexion
  • Virtual try-on rendering: To accurately apply and position cosmetic effects on your face
  • Search and recommendations: To improve product ranking and suggestions based on your interaction over time
  • Model training (anonymized only): Aggregated, de-identified data may be used to improve our shade-matching algorithms and system performance

We do NOT use face data for:

  • Identity verification
  • Advertising targeting or measurement
  • Sharing with government entities
  • Health analysis or diagnosis

Data storage and security:

All facial data is encrypted and stored in Google Cloud infrastructure within secure, access-controlled environments.

Data retention:

  • Active accounts: Data is retained as long as you maintain an active account
  • Deleted accounts: All associated face data is permanently deleted from both active storage and backups within 30 days of deletion request

Third-party sharing:

We use Google Cloud Platform to securely store and process facial data. Google does not have access to user-identifiable information and does not use our data for its own purposes. We do NOT sell, share, or license face data to any third-party advertisers or unrelated entities.