MEMOMI PRIVACY POLICY FOR THE USE OF COLOR MIRROR

Last Revised December 19, 2019

 

This Privacy Policy describes the policies and procedures of MemoMi Inc. ("we", "our" or "us") on the collection, use and disclosure of your information in connection with your use of the COLOR MIRROR (“COLOR MIRROR”). We receive information about you through your user account if you register for an account on the COLOR MIRROR (your “Account”). When you use the COLOR MIRROR, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy.

 

What Does This Privacy Policy Cover?

In Short: This Privacy Policy covers the treatment of your Personal Information gathered when you are using the COLOR MIRROR.

We are committed to protecting your Personal Information and your right to privacy. Throughout this Privacy Policy, “Personal Information” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with an individual or household. These include information such as your photographs or videos, full name, e-mail address and/or telephone number, and if applicable also usage data such as your IP address. Such is the data we collect when you use the COLOR MIRROR.

 

Here we seek to explain to you in the clearest way possible what Personal Information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our COLOR MIRROR. Otherwise, if you have any questions or concerns about this Privacy Policy, or our practices with regards to your Personal Information, please contact at customer@memomi.co.  

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your Personal Information with us.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party social media, services and applications (each a "Third Party Service") that you elect to access through the COLOR MIRROR or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

 

What Information Do We Collect from You?

 

In Short: We may obtain personal information about you from your Account, including the information you submit into COLOR MIRROR such as photographs.

The types of personal information we may obtain include: 

We also may collect personal information typed into forms on the COLOR MIRROR, whether or not the form is submitted.

 

What Information Do We Collect Automatically from You? In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you use the COLOR MIRROR.

We automatically collect certain information when you visit or use the COLOR MIRROR that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with you or your household. This information may not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the COLOR MIRROR and other technical information. This information is primarily needed to maintain the security and operation of the COLOR MIRROR, and for our internal analytics and reporting purposes. 

The technologies we use for this automatic data collection may include:

 

Do We Collect Personal Information of Children?

In Short:  We do not knowingly collect data from or market of children under 13 years of age.  

We do not knowingly collect or solicit Personal Data from anyone under the age of 13. If you are under 13, please do not attempt to register for the COLOR MIRROR or send us any of your Personal Data. If we learn that we have collected Personal Data from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us Personal Data, please contact us at customer@memomi.co.

 

How, and with Whom, Is My Information Shared or Transferred?

In Short:  We only share information either with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.   

It is important to note first that We do not sell your Personal Information.

We may process or share data based on the following legal basis:

 

Additionally, we may need to process your data or share your Personal Information in the following situations:   

 

What Public Information About You and Your Activity on the COLOR MIRROR Can Others View?

In Short: Information you post about you on our COLOR MIRROR may be viewed by others but only if you forward it or post it on social media.

Any Personal Information you share about yourself through social medial may be viewed by others. This includes information you choose to provide openly, including your username, photos, videos, and links to your  social media profiles, which may be displayed to other users to facilitate user interaction within the services. We will not directly reveal user email addresses to other users.

 

Please remember that if you choose to provide Personal Information using social media, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the COLOR MIRROR.

 

What Information Is Disclosed for Our Protection and the Protection of Others?

In Short: We may have to share your Personal Information if legally required to do so.

We reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

 

What Choices Do You Have Regarding Your Information?

In Short: You have several options to control and manage the amount of Personal Information you share with us depending on where you reside.

If you are a resident of the European Union (“EU”), you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Information, as outlined below.

 

  1. Access:

You can request more information about the Personal Information we hold about you and request a copy of such Personal Information.

 

  1. Rectification:

If you believe that any Personal Information we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by updating any of the information contained in your user profile.

 

  1. Erasure:

You can request that we erase some or all of your Personal Information from our systems.

 

  1. Withdrawal of Consent:

If we are processing your Personal Information based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Information, if such use or disclosure is necessary to enable you to utilize some or all of the COLOR MIRROR.

 

  1. Portability:

You can ask for a copy of your Personal Information in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

 

  1. Objection:

You can contact us to let us know that you object to the further use or disclosure of your Personal Information for certain purposes.

 

  1. Restriction of Processing:

You can ask us to restrict further processing of your Personal Information.

 

  1. Right to File Complaint:

You have the right to lodge a complaint about our practices with respect to your Personal Information with the supervisory authority of your country or EU Member State.

 

  1. Transfers of Personal Information:

The COLOR MIRROR are hosted and operated in the United States (“U.S.”) and Japan through our own Application and through our Service Providers. If you do not reside in the U.S. or Japan, laws in the U.S. or Japan may differ from the laws where you reside. By using the COLOR MIRROR, you acknowledge that any Personal Data about you is being provided to us in the U.S. and will be hosted on U.S. servers. You authorize us to transfer, store and process your information in the U.S., and possibly other countries.  

Please note that whenever we transfer your Personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring, where required by law, at least one of the following safeguards is implemented:

 

You may be entitled, in accordance with applicable law, to request a copy of relevant safeguards by contacting us at customer@memomi.co.  

 

 

If you are a California resident and you have provided us with your Personal Information, you have the right to request that we:

  1. Disclose the categories and specific pieces of Personal Information we have collected

 

  1. Disclose the categories of sources from which the Personal Information is collected

 

  1. Disclose the purpose for collecting or selling your Personal Information

 

  1. Disclose the categories of third parties with whom we share your Personal Information

 

  1. Delete any Personal Information about you that we have collected from you, subject to certain exceptions

 

  1. Not sell your Personal Information.

Such requests must be submitted to us in writing at customer@memomi.co.  

 

How Long Do We Retain Your Personal Information?

In Short:  We keep your Personal Information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.  

We will only keep your Personal Information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

Is the Information About You Secure?

In Short:  We aim to protect your Personal Information through a system of organizational and technical security measures, including encryption as required by law. 

Please remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your Personal Information, transmission of Personal Information to and from the COLOR MIRROR is at your own risk. You should only access the COLOR MIRROR; within a secure environment. 

 

What Happens When There Are Changes to this Privacy Policy?

In Short: We may update this Privacy Policy from time to time, so you should review it periodically for updates or review it if you receive a notice of update from us.

The effective date of this Privacy Policy appears at the top of this page. However, we may update this Privacy Policy from time to time. It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat your Personal Information, we will notify you by email to the email address specified in your account or through a notice on the COLOR MIRROR home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our websites and this Privacy Policy to check for any changes.

 

What If I Have Questions or Concerns?

If you have any questions or concerns regarding privacy using the COLOR MIRROR, please send us a detailed message to customer@memomi.co.  We will make every effort to resolve your concerns.