Privacy Policy - Kartek Beauty

Kartek Beauty LLC, a Wyoming corporation, a subsidiary of (“Farasha Holding LLC”, “we”, “our”, “us”) with principal offices at 1700 Northside Drive, suite A7-1535, Atlanta, GA 30318, USA and privacy contact email data@KartekBeauty.com, operates the websites located at the URLs KartekBeauty.com, (collectively, and together with the G. Spotting App, as defined in our Terms of Service), referred to together in this Privacy Policy as the “Website”).

Effective date: September 02, 2022

Scope of Policy

This Privacy Policy explains how we collect, use, disclose and manage your personal information that you provide to us when using the Website or otherwise, as well as our privacy practices. This Privacy Policy applies, without limitation, to any individual or entity that (i) uses the Website, (ii) creates an Account (as defined in our Terms of Service), or (iii) otherwise provides any personal information to us.

Please note that this Privacy Policy contains separate components with varied rights that may apply to you differently depending upon where you live or where you are accessing the Website. (California residents applying for jobs at Kartek Beauty: Please see below under “CCPA Notice for Candidates Applying to Jobs at Kartek Beauty”.)

WHEN YOU ACCESS OR USE THE WEBSITE, OR OTHERWISE PROVIDE ANY INFORMATION TO US, YOU AGREE TO THIS PRIVACY POLICY, INCLUDING THE MANNER IN WHICH WE USE YOUR INFORMATION, WHETHER OR NOT YOU HAVE AN ACCOUNT WITH Kartek Beauty. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES WE SUBSEQUENTLY MAKE TO THIS PRIVACY POLICY, YOU MUST IMMEDIATELY STOP USING THE WEBSITE OR OTHERWISE PROVIDING ANY INFORMATION TO US.

The Website contains links to other websites. This Privacy Policy does not apply to information collected on or through any such third party websites. We are not responsible for the privacy practices of such third parties or the content of their websites. Such third parties have their own privacy policies and you should review those privacy policies to determine their privacy practices.

Information Collected

We collect the following information:

Contact and Account Information: Your name, addresses, telephone numbers, email addresses, date of birth, username, password and any other contact and/or Account information that you provide us either through our Website, our events or in-store;
Service Provider Information: Information about the mobile or internet service provider you are using with your device to access the Website and/or send us messages, including name and IP address.
Messages: The date, time and content of any messages you send to us;
Payment Information: Credit/debit card and other billing information, including cardholder transaction data, card numbers, expiration dates, billing addresses and CVV codes;
Surveys, Quizzes, and Product Testing. We may contact you to participate in surveys or quizzes or participate in product testing. If you decide to participate, you may be asked to provide certain information which may include personal information.
Interactive Features. We and others who use our services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide on the public sections of these features will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.
Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Job Applications. We may post job openings and opportunities on our Website or through other platforms. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications. (See below under “CCPA Notice for Candidates Applying to Jobs at Kartek Beauty” for more information regarding the categories of personal information that Kartek Beauty collects about California residents applying for jobs at Kartek Beauty and the purposes for which we use that information.)
Technical Information:
- IP address and other technical information collected from the servers utilized by you or your vendors, such as information and data that is automatically collected upon visiting the Website (i.e., webpage http headers (home server domain names, internet protocol address, operating system type, browser type and language) and information on what pages you access and other information about the way(s) in which you use the Website).
- Information provided on any application (including the App) or authorization, such as your location, your handset type, your UDID (unique handset code) and any other information you or your mobile device provides to us;
Other: Other information you provide to us when you use the Website or otherwise interact with us.
Information listed above which we aggregate and/or anonymize so that it is not linked to you.

How Information is Collected

We collect information through one or more of the following ways:

the completion of electronic forms found on the Website or on a third party-hosted website, whether via computer or mobile device;
the completion of paper forms provided to us;
SMS (Short Message Service) messages sent via cell phone, or through email and other communications;
telephone calls made to us, or vice versa;
surveys and quizzes;
referring websites or third parties, including social media sites such as Facebook, Twitter, Tumblr, Instagram, Pinterest, YouTube, Google+ and others including by virtue of advertisements placed by us on websites maintained by those third parties;
our affiliates such as Kartek Beauty LLC Limited;
the maintenance and analysis of Website server logs;
events that we host or by visiting our stores; and
“cookies” (small text files placed by us on your computer(s)), single pixel GIF image files (also called “Web beacons”), Website server log analysis and other similar technological means. See “Use of Web Technologies” Section below.

Location information: We collect information about your location based on:

derivations made from the IP address from which you connect; and
if you consent (by accepting on your mobile operating system), the Global Positioning System (GPS) of your device when the App is running in the foreground (together, “Location Information”).

We (and our service providers) use your Location Information to provide you with customised nearby services or value-added services (including marketing) that we think you’d like. Where possible, we may also use Location Information to enhance or localise content and services that you use. If you do not wish to share your GPS location with us, you can switch off GPS functionality on your mobile device. If you otherwise wish to withdraw your consent to us using cell ID data and GPS data, email us at data@KartekBeauty.com.

Certain portions of the Website require that you register for an Account before being able to access them. On those portions of the Website that require registration, we collect information to create your account, as well as to determine specific content, products and services that will be of particular interest to you. By collecting and maintaining accurate information, we learn more about your interests and needs and are better able to provide you with such content and with offers for such products and services.

Use of Information Collected

We use the information we collect:

to authenticate and verify individual identities, including requests to exercise your rights under this policy.
to provide customized information and offers of products and services, including to enable third party services to display customized content and advertising provided by us.
to manage and communicate with you about your account with us, including responding to your questions and providing customer or technical support.
for the purposes of processing payments and fulfilling orders for products or services placed by you, processing your request to use our interest-free payment plans and order fulfillment and tracking.
for statistical purposes.
to publish feedback, personal testimonials, and other information in our editorial publications and online articles.
to provide information about our company such as newsletters or other communications, and to deliver advertising and promotional information from our partners and third party vendors.
to improve our technologies including for the purpose of enhancing your experience on the Website.
to provide marketing messages, promotions, offers of products and services and other content which we think will be of specific interest to you, where you have consented (or not opted out, as applicable).
to process applications if you apply for a job that we post on our Website.
to manage and secure our operations including for detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity; debugging to identify and repair errors with our Website; and auditing relating to interactions, transactions and other compliance activities.
to enforce our agreements and policies
to comply with our legal obligations.

We store or transfer your credit/debit card data in order to more easily provide services to you. If such credit/debit card and other billing information is collected and/or stored, such credit/debit card and other billing information will be collected and transferred over a secure connection in accordance with applicable regulatory requirements, and is used only for processing underlying transactions.

Where you have consented (or not opted out, as applicable), we add your information to our databases to contact you through future emails, postal mailings and SMS text-messaging regarding site updates, upcoming events, new products and services and/or the status of orders placed online. We do not currently use geolocation for purposes of tracking your location when you use the Website, but we reserve the right to do so in the future in order to better target product and service offerings and other information to you.

When you sign up for an account with us, we will send you a welcome email. We will also communicate with you in response to your inquiries, to provide any services you request, to provide newsletters or other updates that you request and to manage your account. In addition, when you register an Account with us, you can consent to our contacting you by email and to receiving our email subscriptions, editorial emails and advertorial emails (see below) from us. If, at any time, you no longer want us to contact you by email and/or receive our email subscriptions, editorial emails and advertorial emails, you can opt out of these functions by changing the preferences in your Account. You can contact customer service by email, telephone or postal mail at the contact information listed below to assist you with any such changes to your Account.

If you have an Account with us, then from time to time, and in addition to emails or email subscriptions sent by us, we will send you emails that contain advertising or other content sponsored by third party retailers or businesses (“advertorial emails”). These advertorial emails are clearly marked as such in the subject line and a note at the top of the article itself. The content is paid for by our sponsors and does not reflect the opinions of our editorial staff. If you prefer not to receive these emails, you can deactivate your Account or otherwise opt-out as provided in the “Opting Out” section of this Privacy Policy below. We send advertorial emails on behalf of the third party sponsors. We do not share your personally identifiable information with such sponsors, except as otherwise provided in this Privacy Policy, but we can sell or share aggregate, non-personal information with such sponsors for any legally permissible purpose.

Sharing of Information Collected with Third Parties

We reserve the right to rent or sell the information we collect from you to third parties.

We also share your information with certain third parties in other circumstances, including when complying with legal process, preventing fraud or imminent harm and/or ensuring the security of our network and services.

We will share certain of your information with third parties for the purposes of fulfilling orders for products or services placed by you. We will share your credit/debit card data only with those directly involved in the processing of the underlying transaction, and who maintain appropriate security measures designed to safeguard such information.

We will share your information with third parties, such as brand partners, to provide you with a product or service you have requested, or to invite you to an event. We may also share your information with business partners with whom we jointly offer products or services. In some cases, we will ask our partners to send event invitations on our behalf.

We will also share certain of your information with third parties for the purposes of providing you with newsletters or other communications.

When we use third parties to assist us in collecting and/or processing your personal information, we typically request that they comply with this Privacy Policy and any other appropriate confidentiality and security measures. However, we make no representation or warranty that such third parties will comply with any such request.

We will provide you with direct access to functionality from other third parties, including Facebook, Twitter, Instagram, YouTube, Pinterest, Spotify, advertising networks and others. The placement of social media widgets, or advertising units on the Website can permit these third parties to see information about you and your activities via cookies, web beacons and other technologies they place and/or access on your browser or device, even if you do not interact with them.

In the event that we go through a business transition, such as a merger, acquisition or sale of our assets, your personal information will likely be among the assets transferred. You will be notified of any such change in ownership or control of your personal information. We transfer your information as an asset in connection with a proposed or actual merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganization, stock sale or other change in control.

We also use and disclose your information to parties connected with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed or continue with such transaction or business relationship or fulfilling any records or other reporting requirements to such parties. Other than to the extent use and disclosure is pursuant to a court order, we will require such parties and successors in interest to treat your information in accordance with this Privacy Policy and to use and disclose it only for the purposes for which it was collected.

We reserve the right to release information to law enforcement or other governmental officials as we, in our sole discretion, deem necessary to comply with applicable law.

Use of Web Technologies

Cookies

A cookie is a small text file that is stored on a user’s computer for record keeping purposes. We use cookies on the Website. We link the information we store in cookies to personally identifiable information that you submit while on the Website. We use both session ID cookies and persistent cookies. A session ID cookie expires when a browser is closed. A persistent cookie remains on your hard drive for an extended period of time. Persistent cookies also enable us to track and target the interests of our users to enhance the experience on the Website. You can remove the persistent cookies by following the directions provided in your internet browser’s “help” file. If you reject cookies, you can still use the Website but your ability to use particular areas of the Website will be limited.

Tracking Pixels

We employ a software technology called tracking pixels (a/k/a web beacons/web bugs/clear gifs) that enables us to better manage the content on the Website by informing us what content is effective. Tracking pixels are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of visitors to a website. In contrast to cookies, which are stored on a user’s computer hard drive, tracking pixels are embedded invisibly on website pages and are about the size of the period at the end of a sentence. We do not tie the information gathered by tracking pixels to your personally identifiable information.

We use tracking pixels in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt-out of these emails, please see the “Opting Out” section of this Privacy Policy below.

Log Files

As is true of most websites, we gather information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the Website, to track the movements of users around the Website and to gather demographic information about our user base as a whole.

What types of cookies and other Web Technologies do we use and how do we use them?

The types of cookies and similar technologies used by us and our partners in connection with the Website can be classified into one of five categories, namely ‘essential Website cookies’, ‘functionality cookies’, ‘analytics and performance cookies’, ‘advertising cookies’, and ‘ social media cookies’. Cookies do a lot of different tasks to ensure you enjoy your visit to our Website, for example, they are used to remember your preferences on our Website, to help you navigate between pages more efficiently, to enable you to log into your account more easily and to make sure the adverts you see on our Website are relevant to you and your interests. We have set out some further information about each category, and the purposes of the cookies we and third parties set in the following table.

You can block these cookies and similar technologies by changing your use of the website.

Type of cookie	What it does
Cookies necessary for essential Website purposes	These cookies are essential to provide you with the Website and any services available through this Website and to use some of its features, such as access to secure areas. Without these cookies, services you have asked for, like transactional pages and secure login accounts, would not be possible.
Functionality Cookies	Functionality cookies record information about choices you’ve made and allow us to tailor the Website to you. These cookies mean that when you continue to use or come back to the Website, we can provide you with our services as you have asked for them to be provided.These cookies allow us to:Save your location preference if you have set your location on your homepage, if applicable, in order to receive a local weather forecast;Remember settings you have applied, such as layout, text size, preferences, and colors;Show you when you are logged in; andStore accessibility options.
Performance Cookies	We use performance/analytics cookies to analyze how the Website is accessed, used, or is performing in order to provide you with a better user experience and to maintain, operate and continually improve the Website.We use Google Analytics, which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our [Website]. The reports disclose website trends without identifying individual visitors. For more information on Google Analytics, see here . You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.These cookies allow us to:Better understand our Website visitors so that we can improve how we present our content;Test different design ideas for particular pages, such as our homepage;Collect information about Website visitors such as where they are located and what browsers they are using;Determine the number of unique users of the Website;Improve the Website by measuring any errors that occur; andConduct research and diagnostics to improve product offerings.
Advertising and Targeting Cookies	As you use our Website, you will notice that it features advertising. We allow third party companies, including advertising companies, to place cookies on our Website.These cookies enable such companies to track your activity across various sites where they display ads and record your activities so they can show ads that they consider relevant to you as you browse the Internet.Cookies also allow us and third parties to know whether you have seen an ad or a type of ad, and how long it has been since you’ve last seen it. This information is used for frequency capping purposes, to help tailor the ads you see, and to measure the effectiveness of ads.We can use information from one device to help personalize your experience on another device.
Social Media Cookies	On some pages of our Website, third parties that provide applications through our Website will set their own cookies in order to track the success of their applications or customize applications for you. Because of how cookies work, we cannot access these cookies, nor can the third parties access the data in cookies used by us. [Some pages of our [Website] will also contain embedded content, such as video content from YouTube, and these sites will set their own cookies.]These cookies are used when you share an article using a social media sharing button on our Website (e.g., Facebook, Twitter, or Google Plus) as the social network that has created the button will record that you have done this. If you are logged in to your account with the third party, the third party will be able to link information about you with your actions via cookies.

In addition to the cookies we use on this website, we also use cookies and similar
technologies in some emails and push notifications which enable us to
understand whether you have opened the email and how you have interacted with
it. If you have enabled images, cookies will also be set on your computer or
mobile device and will also be set if you click on any link within the email.

For
US Users: Do Not Track

When
you use the Website, you may have set your browser or other means used to
access the Website to send “do not track” requests to us. At this time, we do
not respond to such “do not track” requests, although we may choose to do so in
the future.

Security

We
take reasonable precautions to protect the confidentiality and security of your
personally identifiable information by using industry recognized security
safeguards. Unfortunately, no method of transmission over the Internet is
completely secure. Therefore, while we strive to protect your personally
identifiable information within industry standards, we cannot guarantee its
absolute security.

We
maintain physical, electronic and procedural safeguards in connection with the
collection, storage and disclosure of your personally identifiable information.
Our security procedures mean that we will occasionally request proof of
identity before we disclose personal information to you. You are responsible
for protecting against unauthorized access to your password and to your
computer/mobile device. We ask you not to share your password with anyone.

Our
employees are trained and required to safeguard your information. Our internal
controls limit access to personally identifiable information based on job
functionality.

No
Information Collected from Children

The content and services provided by us or our affiliates, sponsors and
advertisers, including without limitation the Website, are not intended for anyone
under the age of 18 and you should not access such content or services if you
are under the age of 18. No information is knowingly collected or retained from
children under the age of 13, nor is any such information knowingly used for
any marketing or promotional purposes whatsoever, either inside or outside the
Website. No part of the Website is designed to attract anyone under the age of
13. Children are not eligible to use any services provided by us and we ask
that children under the age of 13 not submit any personal information to us or
visit the Website.

If you are a parent or guardian and believe your child has uploaded personal
information to our site without your consent, you may contact us at data@KartekBeauty.com.
If we become aware that a child has provided us with personal information in
violation of applicable law, we will delete any personal information we have
collected, unless we have a legal obligation to keep it.

Third Party Ad Server Networks

Our Website uses third parties such as network advertisers to serve advertisements
on our Website and traffic measurement services to analyze traffic on our
Website. Network advertisers are third parties that display advertisements
based on your visits to our Website and other websites you have visited. Third
party ad serving enables us to target advertisements to you. Our Website’s
third party ad network providers, the advertisers, the sponsors and/or traffic
measurement services can themselves set and access their own cookies and other
technologies on your computer and track certain behavioral information
regarding users of your computer via an IP address or other device identifier.
These third party cookies and other technologies are set to, among other
things: (a) help deliver tailored advertisements to you; (b) prevent you from
seeing the same advertisements too many times; and (c) understand the
usefulness to you of the advertisements that have been delivered to you. Note
that any images (or any other parts of a web page) served by third parties in
association with third party cookies can serve as web beacons, which enable
third parties to carry out the previously described activities. Third party
cookies, web beacons and other third party technologies are governed by each
third party’s specific privacy policy, not this one.

To opt out of third-party tracking on our Website use the following tools

You can opt out of the Ad Tech Network by clicking http://www.youronlinechoices.com/opt-out-interface.

If you would like to opt out of having interest-based information collected during
your visits to our Website or other sites, both the National Advertising
Initiative (the “NAI”) and the Digital Advertising Alliance (the “DAA”) offer
opt out tools to assist you in managing your choices. Click http://www.networkadvertising.org/choices/ to
visit the NAI opt out page and click http://www.aboutads.info/choices/ for
the DAA opt out page.

You can visit http://www.networkadvertising.org/understanding-online-advertising/ to
learn more about interest-based advertising and your choices regarding having
this information used by third parties and your “opt out” choices. Opting out
through the DAA or the NAI only means that those DAA or NAI members will no
longer be able to deliver targeted content and/or ads to you, which will affect
our Website as well as other unaffiliated websites, but does not mean you will
no longer receive any targeted content and/or ads. Also, if your browsers are
configured to reject cookies when you visit these opt out pages, or you subsequently
erase your cookies, use a different computer or change web browsers, your opt
out choices could not (or could no longer) be effective.

Opting Out

If you want to be removed from our marketing list and do not want us to send you
email, postal mail or other messages about our products and services, you can
opt out. To do so, please send an email to data@KartekBeauty.com, with the word
“REMOVE” in the subject line.

California Civil Code Section 1798.83 permits California residents to request certain information
regarding our disclosure of such residents’ personal information to third
parties for such third parties’ direct marketing purposes. To make such a
request, please email us at data@KartekBeauty.com.

Privacy Policy Updates

We reserve the right to change this Privacy Policy at any time, so please review
it on a regular basis. Any changes made to this Privacy Policy will be posted
here and we will notify you of any material changes. The date stamp at the top
of the page represents the last day this Privacy Policy was updated. If you
have questions about this Privacy Policy, you can contact us at data@KartekBeauty.com.
By maintaining an Account with us, or by using or accessing any services
provided by us or the Website, you will be deemed to have acknowledged our
Privacy Policy.

Manage Accurate Information

If your personally identifiable information changes, or if you no longer choose to
use our services or the Website, you can contact customer service by email,
telephone or postal mail at the contact information listed below to assist you
with changes to your Account. To the extent your Account closes or becomes
inactive, we will continue to protect your information as described in this
Privacy Policy.

International Users

Kartek Beauty is based in the United States, with our servers and offices headquartered
in the United States. Please be aware that information you provide to us or
that we obtain as a result of your use of the Website, an Account, or any
services provided by us will be processed and transferred to, and be subject to
the laws of, the United States. The privacy and data protection laws in the
United States will be different from similar laws in your country of residence.
By using the Website or an Account, or by providing us with your information,
you consent to the collection, transfer, storage and processing of information
to and within the United States. If our cookies or other software detects IP
addresses located in a country outside the United States, we reserve the right
to deny access to any and all of our services.

EU Users

If you are in the EU, you have certain additional rights and protections under the
law regarding the collection and processing of your personal data.

Legal Basis for Processing

If you are in the EU, we will collect and process your personal data:

To perform our responsibilities under our contract with you (e.g. processing
payments for and fulfillment of the goods you have ordered);
When we have a legitimate interest in collecting and processing your personal data
in order for us to run a successful commercial organization (e.g. to
communicate with you about updates regarding your order, to advertise
products to specifically tailored for you, and send you updates to this
policy);
Where you have given your consent (e.g. to market products to you, to use
Location Information) – please note that you can withdraw your consent at
any time by emailing data@KartekBeauty.com; or
To comply with our legal or regulatory obligations.

Recipients

We share your information with selected recipients. These categories of recipients
include:

cloud
storage providers including Amazon Web Services located in Virginia, and
which currently stores your personal data in Virginia, to store the
personal data you provide and for disaster recovery services, as well as
for the performance of any contract we enter into with you;
IT
service providers (including Segment, located in the United States), that
provide us with SaaS services, who we use to store our customer
relationship management information, etc.;
provided
you have consented, advertisers and advertising networks including Google
and Facebook located in California, and which store your personal data in
California, that require the data to select and serve relevant adverts to
you and others;
analytics
and search engine providers including Google and Heap located in
California and which currently store your personal data in California that
assist us in the improvement and optimization of the website; and

Data Subject Requests

If you are a user in the EU, you have the right to access personal data we hold
about you and to have certain personal data corrected or erased. You also have
the right to data portability, and to restrict certain processing of your data
in certain circumstances. You also have the right to complain to your data
protection authority if you have any complaints about how we process your
personal information.

You have the right to object to our processing of your personal data at any time,
and you can withdraw your consent to marketing at any time.

To make any of these requests please email data@KartekBeauty.com. We will respond
as soon as practicable and no later than one month after receipt of your
request. We will request proof of identification to verify your identity.

We reserve the right to deny or restrict fulfillment of your request in certain
cases, such as when your access to data places another individual’s privacy
rights at risk, or the continued processing or your data is necessary to comply
with a legal obligation. If so, we will notify you of the reason(s) for this denial.

Questions or Complaints

In the event that you have a concern about our collection and processing of
your data, please contact us first at data@KartekBeauty.com and we will do our
best to fix it. You also, have the right to lodge a complaint directly with
your local supervisory authority.

California Residents

The table below explains the categories of information that we have
collected in the past 12 months, the sources of that information, the purpose
for that collection and the categories of third parties with whom we share that
information. (Note: See section below under “CCPA Notice for Candidates
Applying to Jobs at Kartek Beauty” for more information regarding the
categories of personal information that Kartek Beauty collects about California
residents applying for jobs at Kartek Beauty and the purposes for which we use
that information.)

Category	Purpose of Collection	Disclosed to Third Parties
User provided information (e.g. identifiers, such as, first name and last name, email address, phone number)	We use this information to provide the services you request, fulfill your orders, answer and manage your questions or complaints, provide you with information you request, for advertising and marketing purposes, run analytics, statistics and research and to tailor your experience on our services.	We may need to disclose this information to service providers such as our cloud storage, payment processing and interest-free payment plans, order management, shipping fulfilment and tracking, data analytics, logging and operations providers. We may also disclose this information to third parties for advertising and marketing purposes or to jointly offer products and services.
Location Information (geolocation information and commercial information)	We use this information to provide you customized services near you and value-add services near you (including marketing).	We may need to disclose this information to service providers such as our cloud storage, payment processing, order management, shipping fulfilment, data analytics, logging and operations providers.
Survey and quiz responses	We use your survey and quiz responses to improve our services and better understand your preferences.	We may need to disclose this information to service providers such as our cloud storage providers, data analytics and survey and quiz processing providers.
Website and Account usage information (e.g. order history, wait lists, pages viewed, and customer service inquiries)	We use this information to better understand how you use the service and to customize your experience on our services.	We may need to disclose this information to service providers such as our cloud storage, payment processing, order management, shipping fulfilment, data analytics, logging and operations providers.
Device level information (e.g. internet and other network activity information, including ADIDs, cookies, IP address, and other device hardware and software information)	We use this information to protect the security of your account and remember your personalized settings. We may also use certain device level information for advertising and marketing purposes.	We may need to disclose this information to service providers such as our cloud storage providers, data analytics providers and advertising partners.
Inferred Data (e.g. inferred user information, preferences or tastes)	We may use this information to provide you with recommendations and customize your experience, optimize or improve our services, and run analytics, statistics and research.	We may need to disclose this information to service providers such as our cloud storage, data analytics, logging and operations providers.
Audio and Visual Information (the public spaces in our physical locations are protected by CCTV.)	We may use this information for the purpose of preventing crime and for your safety and the safety of our employees.	We may need to disclose this information to service providers such as our security and CCTV providers or to law enforcement.

The California Consumer Privacy Act of 2018 (the “CCPA”) has defined a “sale” to include any transfer of personal information by us to another entity for anything of value. For these purposes, in the past 12 months, we have “sold” (for the purposes of the CCPA) the following categories of personal information:

device level information (e.g. internet and other network activity information, including ADIDs, cookies, IP address, and other device hardware and software information);
commercial Information (e.g., purchases, wait lists and pages viewed);
inferred Data (e.g. inferred user information, preferences or tastes); and
location Information (geolocation information and commercial information)

to third parties for a business or commercial purpose.

As applicable under the CCPA, from January 1, 2020, if you are a California resident, you may make requests to us as set out below. We will review all requests received and determine the extent to which and how to respond. We will not discriminate against any California resident who makes such requests.

Right to access/know

You may request from us a list of: (i) the personal information that we have collected about you; (ii) the categories of third parties to whom we have disclosed your personal information; and (iii) the categories of third parties to whom we have sold your personal information. You have the right to up to two (2) access requests each twelve (12) months.

Right to delete your personal information

You may request to delete your account and your personal information.

Right to opt-out from the sale of your personal information

You may request, at any time, to direct us to stop “selling” (for the purposes of the CCPA) your personal information.

Other Requests

As a California resident, you may contact us with any questions or to request a list of third parties to whom we may disclose your information for such third parties’ marketing purposes and the categories of Information we may disclose.

See the Contact Us section below to make such requests.

Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at data@KartekBeauty.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.

Data Retention

We will retain your information as long as needed to enable you to access the Website or otherwise interact with you, and for as long as you or we can bring a legal claim.

After you have terminated your use of our services, we may store your information in an aggregated and anonymized format.

Contact Us

If you have any questions or suggestions regarding this Privacy Policy, please contact us as follows:

By mail:

Kartek Beauty

1700 Northside Drive, Suite A7-1535

Atlanta, GA 30318

Alternatively, regular mail can also be directed to our EU representative by addressing it to:

By mail: Kartek Beauty LLC Limited, Clay Barn Ipsley Court, Berrington Close, Redditch, Worcestershire, United Kingdom, B98 0TJ

By email: data@KartekBeauty.com

CCPA Notice for Candidates Applying to Jobs at Kartek Beauty

California law requires that we provide you this notice about the collection and use of your personal information. We encourage you to read it carefully. Upon request, this notice can be made available in alternative formats, such as large print or audio. Please contact data@KartekBeauty.com, and an alternative format will be provided to you so you can access the information in this notice.

1. Introduction

This CCPA notice regarding job applicants (“CCPA Notice”) describes the categories of personal information that Kartek Beauty collects about California residents who apply or are recruited for a job with us (“Candidates”), and the purposes for which we use that information.

For purposes of this CCPA Notice, “personal information” has the meaning given in the CCPA, but excludes information exempted from the CCPA’s scope.

This Notice does not create or form part of any contract for employment or otherwise.

If you have questions about this Notice, please contact us at data@KartekBeauty.com or at the address and/or phone number below:

Kartek Beauty LLC

1700 Northside Drive, Suite A7-1535

Atlanta, GA 30318

2. Information we collect about Candidates

2.1 Categories of personal information
The categories of personal information we may collect and process during the application and recruitment process include:Contact information, such as home address, telephone number, and email address;
Information from job application materials or recruiters, such as your job application, resume or CV, cover letter, references, education history, work history, whether you are subject to prior employer obligations, and information that referrers provide about you;
Professional qualifications, such as licenses, permits, memberships, and certifications;
Information from the application process, such as any phone-screens, interviews, evaluations and outcomes of take home tests and other recruiting exercises;
Immigration status and other information that would allow us to verify your employment eligibility;
Biographical information, such as name, gender, date of birth, professional history, references, language proficiencies, education details, and information you make publicly available through job search or career networking sites;
Job preferences, such as desired position and compensation, location preferences and willingness to relocate;
Employment history;
Background check information, such as information necessary to complete background, credit, and/or other checks when permitted by law, and information received during these checks;
Information needed to understand and assess accommodation requests regarding potential disabilities or other health conditions; and
Other information you provide to us.

Providing personal information to us is voluntary. However, if you do not provide sufficient information, we may be unable to consider your application or, if you are hired, your subsequent promotion, transfer or relocation.

In certain cases, we may ask you for additional information for purposes of complying with applicable laws. We may also inquire about criminal records. We will do so only where permitted by applicable law.

2.2 Sources of personal information
We collect personal information from you when you apply for a job and throughout the job application or recruitment process. We may also collect your personal information from other sources and combine it with the personal information you provide us. For example, we may collect your personal information from:Job board websites you may use to apply for a job with us;
Prior employers that provide us with employment references;
Professional references that you authorize us to contact;
Pre-employment screening services, such as background check providers (where permitted by law);
Employment agencies and recruiters;
Your educational institutions;
Your public social media profile or other publicly-available sources;
Online activity information that we and our service providers collect using server logs, “cookies” and similar technologies. Please see our Privacy Policy above for more information.
Other Company personnel.

3. How we use personal information about Candidates

3.1 Purposes for which we use personal information

We may use the categories of personal information above for the following purposes:

Recruitment management. Managing recruitment generally, such as:

Operating the applicant tracking system we maintain through Kartek Beauty.com, Greenhouse or any other site to which this Notice is posted (collectively, the “Careers Site”);
recruiting, interviewing and evaluating job Candidates;
conducting background checks and other pre-employment screening (where permitted by law);
analyzing and improving our application and recruitment processes;
accommodating disabilities or health conditions;
communicating with you regarding your candidacy, opportunities with Kartek Beauty or about the Careers Site and any changes to applicable terms or policies; and
other business operations.

Compliance, safety, and fraud prevention, such as:

complying with or monitoring compliance with legal and other requirements, such as reporting and equal opportunities monitoring requirements, where applicable;
complying with internal policies and procedures;
complying with lawful requests and legal process, such as responding to subpoenas or requests from government authorities;
protecting our, your or others’ rights, safety and property;
investigating and deterring against fraudulent, harmful, unauthorized, unethical or illegal activity, or conduct in violation of our policies or procedures; and
sharing information with government authorities, law enforcement, courts or private parties where we have a good-faith belief it is necessary for the foregoing purposes.

Analytics. Creating anonymous, aggregated or de-identified data that we use and share to analyze our application and recruitment activities, business and for other lawful business purposes.

3.2 Sharing personal information
We may share your personal information with other parties as necessary for the purposes described above. For example, we may share your personal information with:Affiliates. Our corporate parent, subsidiaries, and other affiliates under the control of our corporate parent, for purposes consistent with this Notice or to operate shared infrastructure, systems and technology.
Kartek Beauty service providers. Companies that provide us with services that help us manage the recruiting process and/or operate our business, such as job boards, recruiters, job placement agencies, interviewing and testing, pre-employment screening, interview travel booking and expense reimbursement (where applicable), relocation (where applicable), and recruitment analytics.
Government authorities, law enforcement and others. Government authorities, law enforcement, courts, and others as described in the compliance, safety and fraud prevention section above.
Business transfers. Parties to transactions and potential transactions whereby we sell, transfer or otherwise share some or all of our business or assets, including your personal information, such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
Professional advisors. Lawyers, financial consultants, immigration advisors, and other outside professional advisors.
Customers and business partners. Customers, other companies and individuals with whom Kartek Beauty does business or is exploring a business relationship.

4. Other information about this Notice

4.1 Third parties

This Notice does not address, and we are not responsible for, the practices of any third parties, which have their own rules for how they collect and use your personal information. Our links to third party websites or services are not endorsements.

4.2 Changes to this Notice

We reserve the right to change this Notice at any time. The “Effective Date” heading at the top of this Notice indicates when it was last revised. Any changes will become effective when we post the revised notice on our Careers Site.

4.3 Children

The Careers Site is not intended for minors under the age of 18.

5. Candidate obligations

Among other obligations, including without limitation the obligation to provide complete and accurate information in recruiting documents and processes, it is your responsibility to ensure that information you submit does not violate any third party’s rights.

You should keep your personal information on file with Kartek Beauty up to date and inform us of any significant changes to it.

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