Effective Date of Current Policy: May 24, 2018
This Policy applies to all Glamourgirlz’s operating divisions, subsidiaries, affiliates, and branches, and any additional subsidiary, affiliate, or branch of Glamourgirlz that we may subsequently form.
2. Transparency/Notice –What Personal Information do we collect and how we use it?
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Glamourgirlz and the requirements of applicable law. Some of the ways that Glamourgirlz may collect Personal Information include:
You may provide Personal Information directly to Glamourgirlz through interacting with the Services, participating in surveys, registering to receive our Newsletters, during events such as sweepstakes, and requesting Services, or information.
As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
1. Types of Personal Information we collect
Glamourgirlz collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors and guests (collectively “Individuals”):
- Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering to receive our Newsletters, participating in surveys, sweepstakes or contests, or otherwise interacting or requesting information on the Services, we may ask you to provide some or all of the following types of information:
- Communication with Us. We may collect Personal Information from you, such as your name, postal address, email address and phone number when you chose to request information about our Services, register for our Newsletter, or otherwise communicate with us.
- Surveys. From time to time, we may you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our Site and/or Services and in any manner consistent with the policies provided herein.
- Posting on the Site. Glamourgirlz may offer publicly accessible pages or blogs on the Site. You should be aware that, when you disclose information about yourself in on Glamourgirlz’s publicly accessible pages or blogs, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
- Registration for Sweepstakes or Contests. Occasionally, Glamourgirlz may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. In compliance with the laws of your jurisdiction, as a participant you will have the opportunity to opt out of any communications that are not related to awarding prizes.
- Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
- Information from Other Sources. We may receive information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Services through a Third-Party application, such as an App Store or social network site (“SNS”), we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your s on the SNS. This supplemental information allows us to verify information that you have provided to Glamourgirlz and to enhance our ability to provide you with information about our business and Services.
2. How do we use the information we collect?
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
- To Provide Services or Information Requested. Glamourgirlz may use information about you to fulfill requests for Services or information, including information about potential or future Services, including to:
- conduct and process transactions with you;
- Allow you to register for events.
- Administrative Purposes. Glamourgirlz may use Personal Information about you for its administrative purposes, including to:
- measure interest in our Services;
- improve our Services and develop new services;
- protect our Services, systems, information, employees, business partners, service providers, users, customers or others;
- verify Individual identity;
- prevent potentially prohibited or illegal activities; and
- process payment for Services purchased.
- Marketing Glamourgirlz Services. Glamourgirlz may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Glamourgirlz may provide you with these materials by email, as permitted by applicable law. Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and services that may be of interest to you;
- To provide Services to you and our sponsors;
- For other purposes disclosed at the time that Individuals provide Personal Information; or
- Otherwise with your consent.
You may us at any time to opt out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.
- Research and Development. Glamourgirlz may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Glamourgirlz may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
- Email. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails and Newsletters from us with information on Glamourgirlz’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.
- Anonymous and Aggregated Information Use. Glamourgirlz may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Glamourgirlz’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Glamourgirlz may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Glamourgirlz and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
- Sharing Content with Friends or Colleagues. Glamourgirlz’s Services may offer various tools and functionalities. For example, Glamourgirlz allows you to provide information about your friends through our referral services, such as “Tell a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Glamourgirlz or any other Third Parties for any other purpose.
- Other Uses. Glamourgirlz may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3. Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
- Cookies: We may utilize “cookies” to maintain a record of your visits and to improve the content and Services. Cookies are text files placed in your computer’s browser to store your preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
- Pixel Tags/Web beacons: A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
- Analytics. We may use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
- Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Site or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt out of the Technologies we employ on our Site and Services, you may do so by blocking, deleting, or disabling them as your browser or device permits.
4. Third-Party Websites and Social Media Platforms
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Glamourgirlz does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
5. Third-Party Payment Processing
When you make purchases through the Services, we process your payments through a Third-Party application, including the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”) and SNS such as Facebook. The Third-Party application may collect certain financial information from you to process a payment on behalf of Glamourgirlz, including your name, email address, address and other billing information.
3. With whom do we share that information?
- We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) customer service activities; (iv) payment processing; and (iv) in connection with the provision of the Site. Glamourgirlz has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
- Business Partners. Glamourgirlz may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Glamourgirlz may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Glamourgirlz. Glamourgirlz requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Glamourgirlz provided them.
- Displaying to Other Users. The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.
- Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, Glamourgirlz may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Glamourgirlz related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt out of such sharing at no cost by following the instructions in Section 6 below.
- Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Glamourgirlz policies or contracts; (v) to collect amounts owed to Glamourgirlz; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
4. Do we collect information from children?
Our Services are not intended for and we do not knowingly collect information from children under the age of 13. If you believe that your child has registered with our Services or that we have collected information from your child, please us immediately so that we can remove that information from our database.
5. What security measures do we take with respect to your information?
We employ reasonable security measures to protect the security and confidentiality of the information that we collect from you (including your Personal Information). However, we cannot guarantee the security of your information or that any communication or transmission of such information over the Internet will be entirely secure.
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
6. Opt-out rights (rights to object to processing)
We offer you choices regarding the collection, use and sharing of your Personal Information and we’ll respect the choices you make. Where you have consented to Glamourgirlz’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by ing. Please note that if you decide not to provide us with the Personal Information that we request, you may not be able to access all of the features of the Services. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Site and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
- Mobile Devices. Glamourgirlz may occasionally send you push notifications through our App with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. Glamourgirlz may also collect location-based information if you use our App. You may opt out of this collection by changing the settings on your mobile device.
- “Do not Track”. Our Site does not have the capability to respond to “Do Not Track” signals received from various web browsers.
- Cookies and Ad Tracking. As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at , or and . You can also choose not to be included in Google Analytics .
7. International Transfer
You agree that all Personal Information collected via or by Glamourgirlz may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Glamourgirlz, you explicitly consent to the storage of your Personal Information in these locations.
8. Rights of Access, Rectification, Erasure, and Restriction
Although Glamourgirlz makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Glamourgirlz is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Glamourgirlz determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a point for any further inquiries. To protect your privacy, Glamourgirlz will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
9. Data Retention
10. International Users
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
11. Redress/Compliance and Accountability
12. Your California Privacy Rights
California residents may request and obtain from us, once a year, free of charge, a list of third parties, if any, to which we disclosed their Personal Information for direct marketing purposes during the preceding calendar year and the categories of Personal Information shared with those third parties. If you are a California resident and wish to obtain that information, please submit your request by sending us an email atwith “California Privacy Rights” in the subject line or by writing to us at 30 Vandam Street, Floor 3, New York, NY 10013.
- New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Glamourgirlz will endeavor to comply with the law or contract.
The following capitalized terms shall have the meanings herein as set forth below.
- “Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Glamourgirlz or to which Glamourgirlz discloses Personal Information for use on its behalf.
- “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
- “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- “Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
- “Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Glamourgirlz or Glamourgirlz’s Agents.
15. Revision History
Title (Effective Date)