Privacy Policy

PATTERN Privacy Policy 

Last Updated 09/09/19  

Welcome! This website patternbeauty.com (the “Site”) is owned and operated by PATTERN Beauty, LLC, a Delaware limited liability company headquartered in Los Angeles, California ("PATTERN", "we", "our" or "us"). This Privacy Policy describes our privacy practices and applies to your use of this Site, including interactive features, platforms, marketplace, widgets, plug-ins, applications, content, downloads of the Site and other online services that we own and control and that post a link to this Privacy Policy, regardless of how you access or use the Site, whether via personal computers, mobile devices or otherwise (collectively with the Site,  the “Service”).

However, this Privacy Policy does not apply to data we receive from third parties, unless we combine such data with Personal Data (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Service (unless otherwise stated below), and does not govern the data practices of third parties that may interact with our Service.  

To the extent we provide you notice on our Service of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.  In addition, please review the Service’s Terms and Conditions of Service, which governs your use of the Service.

If you are located in the European Economic Area (“EEA”), it is important you read this Privacy Policy, in particular to Section 8.

By using our Service, you agree to the Terms and Conditions of Service and consent to our Privacy Policy, including the collection, use, sharing and disclosure of your information and data, and other activities as described in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use this Service.

Table of Contents

  1. Information We Collect
  2. Tracking Technologies and Use of Cookies
  3. How We Use Your Information
  4. Why and When We Share Your Information
  5. Your Choices
  6. Transfer of Your Information
  7. Additional Information Regarding Individuals in the EEA
  8. Security
  9. Children
  10. Changes to This Privacy Policy
  11. How to Contact Us
  12. California Residents: Your California Privacy Rights

  1. Information We Collect

We may collect and store information about you in connection with your use of the Service, including any information you transmit to or through the Service.  Such information may be collected in three ways: (1) you voluntarily provide information to us, such as by creating an account, or signing up for email alerts, (2) we collect information automatically, such as through tracking tools like browser Cookies, and/or (3) from third parties, such as ad networks or social networks, may provide information to us.  Each of these methods is described in more detail below.

  1. Information You Choose to Provide

We may ask you to provide us with certain categories of information, such as: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, phone number, gender, birth date, credit card, mailing address, username and password, location and email address (“Personal Data”).

The following are some examples in which you may choose to provide Personal Data to us:

  • When you choose to register for an account to use the Service;
  • When you purchase something from us or otherwise engage in a transaction with us;
  • When you contact us for any reason (e.g.  through “contact us” forms), including for technical support or customer service; or
  • When you choose to subscribe to our emails or to receive other information from us.

  1. Information Collected Automatically When You Use Our Service

In addition to any information that you submit to us through the Service, we and our third-party service providers may collect or store certain information automatically (or passively) whenever you visit or otherwise interact with the Service (“Usage Information”). We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”), which may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (each a “Device”). We typically aggregate the data that we collect automatically and use it in statistical form to determine trends among groups of users, rather than using it to identify individuals. To the extent we associate Usage Information with Personal Data that we collect directly from you through the Service, or if the information collected automatically identifies you  individually, we will treat it as Personal Data.  

The following are examples of Usage Information we may collect:

  • Your IP address, UDID or other unique identifier (“Device Identifier”).  A Device Identifier is a number that is automatically assigned to your Device used to access the Service, and our computers identify your Device by its Device Identifier;
  • Other Cookies also collect information on your behavior by collecting referring URLS (where our visitors come from, which banners they clicked on and which directed them to our Service), pages accessed, times of visits. 
  • Your Device location.

  1. Information Third Parties Provide About You

We may supplement the information we collect directly from you on our Service with outside records from third parties (e.g., delivered by advertising agencies, analytics providers, etc.)  for various purposes, including so that we can deliver the products you have requested, to enhance our ability to serve you, to tailor our content to you, and to offer you opportunities that may be of interest to you.

We collect this information:

  • when you use a third-party service like Google, or log into the Service via a social media account such as Facebook.  For example, social networks may provide us with certain information about you from your profile on their website such as contact information, demographics, and other information you provided to that website such as your photo, user name, and potentially any and all information that you agreed the social network or other party could provide to us.
  • when you request information from or provide information to third parties.  For example, you may be presented with an option on our Service to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it.

Please note, third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy.  For example, if you post content to a third-party service through the Service, that third party service will also receive that content, which will be visible to anyone that has access to it through that third-party service. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices or use of their use of your information. You should review the applicable third-party privacy policies before using such third-party tools on our Service.

  1. Tracking Technologies and Use of Cookies

We may use various methods and technologies to collect and store information automatically (“Cookies”) when you use or interact with the Service. This information may be stored or accessed using Cookies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (each, a “Device”).

A few of the Cookies include, without limitation, the following (and subsequent technology and methods later developed):  Cookies, advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID), web beacons, tags, embedded scripts, local shared objects such as HTML5 and Flash (sometimes called "flash cookies"), advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID), Browser Fingerprinting, E-Tags and similar technology in connection with your use of the Service, third party websites and mobile applications. For more information about some of these Cookies click here.

 The purposes for which we use Cookies in the Service include:

  • Processes
    • Intended to make the Service work in the way you expect. For example, we use a Cookie that tells us whether you have already signed up for an account.
  • Authentication, Security, & Compliance
    • Intended to prevent fraud, protect your data from unauthorized parties, and comply with legal requirements. For example, we use Cookies to determine if you are logged in and to remember you and your Device and for fraud prevention.
  • Preferences
    • Intended to remember information about how you prefer the Service to behave and look. For example, we use a Cookie that tells us information from that provider to facilitate your browsing such as languages preferences, or saving the content of your shopping basket or wish list.
  • Notifications
    • Intended to allow or prevent notices of information or options that we think could improve your use of the Service. For example, we use a Cookie that stops us from showing you the signup notification if you have already seen it.
  • Advertising
    • Intended to make advertising more relevant to users and more valuable to advertisers. For example, such information will allow us to enhance the Service, have a better understanding of the products and services you would prefer, and offer you more personalized communications and/or more personalized content on the Service.
  • Sharing Content
    • We may include in the Service the possibility to share content with third parties or to let other persons know you browsed our Service. Such is the case for instance of “Like” and “Share” functionalities offered by social network platforms (“Facebook”, “Twitter”, etc.)
  • Analytics
    • Intended to help us understand how users use the Service. For example, we use Cookies for web analytics to measure the web sites activity and determine the areas of the Service which are the most visited, hence improving visibility of our content.

 

  1. How We Use Your Information

We and our third-party service providers may use your information to:

  • to process your order, respond to your requests or questions, and manage your complaints: for example, we use your information to process your order and deliver your products. Or, we may use your information to send you information you requested, or to communicate with you about your account or our relationship with you, for example, we may contact you about changes to the Service or about service updates. We may also contact you about feedback or about this Privacy Policy or the Terms and Conditions of Service. In such case, your information is processed to perform the contract we have with you.
  • improve the Service’s quality, engage in research and analysis relating to the Service, track usage of the Service, and provide feedback to third party advertisers that are listed on the Service. We may use your information to customize your experience with the Service and to tailor our marketing activities to fit your needs and interests as we believe that it is also in our legitimate business interest to better serve you and respond to your needs.
  • provide customer support, message you, back up our systems, allow for disaster recovery, enhance the security of the Service.
  • for marketing purposes: we may use your information to contact you, subject to your consent when applicable, about new products and special offers we think you will find valuable.
  • for security purposes: we may use information to protect PATTERN, you, and our website the Service against fraud, theft or any wrong doing which may affect our activity business operations, as it is our legitimate business interest to ensure the security of our activity online and offline to comply with legal obligations the Service.

  1. Why and When We Share Your Information

We may share non-Personal Data, such as aggregated user statistics, with third parties such as ad networks and content distributors. For example, we may disclose the number of users that have been exposed to, or clicked on, advertisements.

Further, we may share your Device Identifiers with third parties along with data related to you and your activities.  We do not share your Personal Data that we have collected directly from you on the Service with third parties for those third parties’ direct marketing purposes unless you have consented (either through an opt-in our opt-out opportunity) at the time you provide your Personal Data.  

In addition, we may share the information we have collected about you, including Personal Data, as disclosed at the time you provide your information and as described below (or otherwise in this Privacy Policy) for various purposes, including:

  • where we have your consent to do so.  For example, to provide you with services that you have requested  and that we have agreed to provide to you, such as our products, customer services, and third-party social network connectivity;
  • as reasonably necessary in order to provide the Service to you (for example, by providing your Personal Data to service providers we may use to fulfill your order) or to protect the rights, property, or safety of PATTERN , our users, or others;
  • as we reasonably believe is permitted by law or regulation or as is necessary to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions of Service and/or any other agreement with you;
  • with our parent companies and affiliates (“Affiliates”) and/or if there is a sale of the assets of PATTERN or corporate restructuring, or as a result of a change of control of PATTERN or one of its affiliated companies, or in preparation of any of these events. Any third party to which PATTERN transfers of sells PATTERN ' assets will have the right to continue to use the Personal Data and other information that you provide to us in the manner set out in this Privacy Policy;
  • We also may share certain limited information, such as Device identifiers, with advertisers and other marketing partners for purposes of gauging the effectiveness of advertising and other marketing strategies; and
  • Third Party Service Providers.  We may also share your information with our service providers if necessary to enable them to provide services to us, such as hosting the Service, designing and/or operating the Service’s features, network security, tracking the Service’s activities and analytics, payment processing, marketing of the Service, and enabling us to perform other administrative services and functions.  We may also share information from or about you with these third-party providers so that they can perform their services or complete your requests. These third-party providers may share information with us that they obtain from or about you in connection with providing their services or completing your requests. Third-party analytics and other service providers may set and access their own Cookies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Data, about you.  We are not responsible for those third-party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.

  1. Your Choices

We provide you with choices about whether to provide us with Personal Data and whether it is shared. We generally only ask you for Personal Data that is necessary to provide the service you request. You can choose not to give us the Personal Data we request, as described in the “Information You Choose to Provide” section of this Privacy Policy. However, in some cases, if you decide not to provide the Personal Data we request, to perform a contract or when required by law, you will not be able to receive the product or service you ordered or otherwise register on our Service.  

Other examples of your choices include:

  • If you have elected to receive direct marketing communications from us, you can change your mind at any time by following the opt out link in any marketing communication that is sent to you.
  • You can browse our Service without providing any Personal Data. We may collect some limited information automatically, as described above.
  • You may be able to limit our sharing of some of this information through your browser or mobile device settings, as further described below.
  • You can change your privacy settings on third-party websites, such as social networks, which may stop or limit our receipt of information from those other websites. You also may choose not to use social features we make available on the Service. If you choose to use these features, please keep in mind that any Personal Data you post  will be visible to others, such as including your email address in a forum or during a chat.
  • You may change your browser settings or take other steps to block, manage, or delete Cookies. Not all of our Services currently respond to browser “do not track” signals, so you will need to use your browser settings to effectively manage Cookies. In some cases, blocking or disabling Cookies may cause our Services not to work as intended and some features may not be available.
  • You can limit interest-based advertising by opting out at www.aboutads.info/choices/ or www.networkadvertising.org/choices/. If you are located in Europe, more information is available at www.youronlinechoices.eu/.  Please note that opting out does not prevent the display of all advertisements to you.
  • You may also be able to reset your mobile advertising identifier or limit ad tracking altogether using the settings in your phone.

You can also amend your choices by sending an email to us as detailed in the “How to Contact Us” section below.

  1. Mobile Device Tracking

As of the Effective Date of this policy, Apple and Google offered the owners of devices that use their operating systems (iOS and Android) with options for limiting tracking and targeting in relation to ads. Please note that changing any of these settings does not prevent the display of certain advertisements to you. PATTERN does not control your Device-level opt-out processes and is not responsible for any choices you make through such a mechanism or for the continued availability, accuracy, effectiveness, or location of that mechanism.

  • If you use an Apple device, go here.
  • If you use an Android device, navigate to the Google Settings page, select Ads and then choose to reset your Android Ad ID or opt-out of personalized ads.
  • To learn about options for many mobile ad networks, go here.

  1. Transfer of Your Information

To provide our Service, we may transfer information about you to other jurisdictions where we do business.  When you use our Service, you acknowledge that we may transfer information about you, including Personal Data, as described in this Privacy Policy.

We will transfer your Personal Data for any of the purposes identified in this policy to our subsidiaries, affiliates, service providers, and business partners that may be located outside of the jurisdiction where you are located.  The laws in those jurisdictions may not provide the same level of data protection compared to the laws in your country.  However, we will treat your Personal Data as subject to the protections described in this Privacy Policy.

If you are located in the European Union (“EU”) or EEA please see Section 7 for more information regarding transfers of Personal Data from the EU or EEA to locations outside of the EEA.  

  1. Additional Information Regarding Individuals in the EEA

  2. Legal basis for processing Personal Data of individuals in the EEA.

We will only use your Personal Data for the purposes for which we collect as outlined below and in Section 3 (How we use your information).  Please note that we may process your Personal Data without your knowledge or consent, in compliance with the applicable data protection laws.

PURPOSE(S) FOR PROCESSING

LEGAL BASIS FOR PROCESSING

Processing, tracking and completing purchase,
return and similar transactions.

  • The processing of your Personal Data is necessary to perform a contract or enter into a contract with you
  • The processing of your Personal Data is necessary for us to comply with legal and regulatory obligations
  • The processing is necessary to support our legitimate interests in managing our business (or those of a third party) provided such interests are not overridden by your interests and rights
To manage and administer your loyalty account

Sending you marketing information, newsletters
and other promotional communications, including
through direct mail offerings 

  • Where you have given consent to the processing of your Personal Data for direct marketing – which you may withdraw at any time
  • The processing is necessary to support our legitimate interests to promote our products and manage our business (or those of a third party) provided such interests are not overridden by your interests and rights

Improve our products and services,  carry out
market research, or perform data analytics

 

  • The processing is necessary to support our legitimate interests in managing our business (or those of a third party) provided such interests are not overridden by your interests and rights
  • Where you have given consent to the processing of your Personal Data for direct marketing – which you may withdraw at any time

For the prevention and detection of fraud, or other
unlawful activities

 

  • The processing of your Personal Data is necessary for us to comply with legal and regulatory obligations
  • Where you have given consent to the processing of your Personal Data for these purposes – which you may withdraw at any time

To manage our relationship with you

  • The processing of your Personal Data is necessary to perform a contract or enter into a contract with you
  • The processing is necessary to support our legitimate interests in managing our business (or those of a third party) provided such interests are not overridden by your interests and rights
  • Where you have given consent to the processing of your Personal Data for direct marketing – which you may withdraw at any time

Notifying you of product recalls or providing
other information concerning products you
have purchased

  • The processing of your Personal Data is necessary to perform a contract or enter into a contract with you
  • The processing is necessary to support our legitimate interests in managing our business (or those of a third party) provided such interests are not overridden by your interests and rights
  • The processing of your Personal Data is necessary for us to comply with legal and regulatory obligations
  • The processing is necessary to protect your vital interests and/or those of a third party



We may determine later that another necessary purpose which is compatible with the original purpose.  If you wish to obtain information as to how the processing for the new purpose is compatible with our original purpose, please contact us by email at hello@patternbeauty.com .

If we need to use your Personal Data for an unrelated purpose, we will notify you and provide an explanation of the legal basis which allows us to do so.

Legal basis for processing Usage Information relating to Individuals in the EEA.

  

PURPOSE(S) FOR PROCESSING

LEGAL BASIS FOR PROCESSING

To improve the Service or our products or services,
to customize your experience on the Service,
or to serve you specific content that is relevant to you

  • The processing is necessary to support our legitimate interests in managing our business (or those of a third party) provided such interests are not overridden by your interests and rights

 

  • Where you have given consent to the processing of your Personal Data for direct marketing – which you may withdraw at any time 

To contact you with regard to your use of the Service
and, in our discretion, changes to the Service or related
terms or policies

For internal business purposes, including to help us
understand how our Service is navigated and used



What additional rights do you have if you are in the EEA?

If you are located in the EEA, you have several rights in relation to your Personal Data under applicable privacy and data protection laws, which may be subject to certain limitations and restrictions. We endeavor to respond to any valid requests within one month, unless such request is complex or you have made repeated requests, in which case we aim to respond within three months. We will inform you of any such extension within one month of receipt of your request, together with the reasons for the delay. You will not be charged a fee to exercise any of your rights unless your request is clearly unfounded, repetitive or excessive, in which case we will charge a reasonable fee in the circumstances or refuse to act on the request. If you wish to exercise any of these rights, please contact us using the contact details set out in Section 12 below. We may request proof of identification to verify your request.

YOUR RIGHT

WHAT THIS MEANS

RIGHT TO WITHDRAW CONSENT

If we are processing your Personal Data on the legal basis of consent, you are entitled to withdraw your consent at any time. However, the withdrawal of consent would not invalidate any processing we carried out prior to your withdrawal based on your consent.

RIGHT OF ACCESS

You can ask us to confirm whether we are processing your Personal Data and request a copy of that Personal Data. You can also ask that we provide additional information, including what Personal Data we have and why we have it, who we disclose it to (including any international transfers outside the EEA), how long we keep it, what rights you have, how you can make a complaint to the supervisory authority, where we obtained your Personal Data, and whether we have carried out any automated decision-making as further described below. 

RIGHT TO RECTIFICATION

You have the right to request that we correct any inaccuracies in the Personal Data we hold about you and complete any Personal Data where this is incomplete.

RIGHT TO ERASURE (‘RIGHT TO BE FORGOTTEN’)

You have the right to request that your Personal Data be deleted in certain circumstances including:

  • The Personal Data are no longer needed for the purpose for which they were collected;
  • You withdraw your consent (where the processing was based on consent);
  • You object to the processing and there are no overriding legitimate grounds justifying us processing the Personal Data (see Right to Object below);
  • The Personal Data have been unlawfully processed; or
  • To comply with a legal obligation.

However, this right does not apply where, for example, the processing is necessary:

  • To comply with a legal obligation; or
  • For the establishment, exercise or defense of legal claims.

 

RIGHT TO RESTRICTION OF PROCESSING

You can ask that we restrict your Personal Data (i.e., keep but not use) where:

  • The accuracy of the Personal Data is contested;
  • The processing is unlawful but you do not want it erased;
  • We no longer need the Personal Data but you require it for the establishment, exercise or defense of legal claims; or
  • You have objected to the processing and verification as to our overriding legitimate grounds is pending.

We can continue to use your Personal Data:

  • Where we have your consent to do so;
  • For the establishment, exercise or defense of legal claims;
  • To protect the rights of another; or
  • For reasons of important public interest.

RIGHT TO DATA PORTABILITY

Where you have provided Personal Data to us, you have a right to receive such Personal Data back in a structured, commonly-used and machine-readable format, and to have those data transmitted to a third-party data controller without hindrance but in each case only where:

  • The processing is carried out by automated means; and
  • The processing is based on your consent or on the performance of a contract with you

RIGHT TO OBJECT

You have a right to object to the processing of your Personal Data in those cases where we are processing your Personal Data in reliance on our legitimate interests. In such a case we must stop processing your Personal Data unless we can demonstrate compelling legitimate interests which override your interests. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

AUTOMATED DECISION-MAKING

You have a right not to be subjected to decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affects you other than where the decision is:

  • Necessary for entering into a contract, or for performing a contract with you (e.g., your policy of insurance);
  • Based on your explicit consent – which you may withdraw at any time; or
  • Is authorized by EU or Member State law.

 

Where we base a decision solely on automated decision-making, you will always be entitled to have a person review the decision so that you can contest it and put your point of view and circumstances forward.

RIGHT TO COMPLAIN

If you are not satisfied with our use of your Personal Data or our response to any request made by you to exercise any of your rights, you have the right to lodge a complaint with the local data protection supervisory authority at any time.

 

  1. Transfers of Personal Data out of the EEA

If you are located in the EEA, the Personal Data we collect from you may be transferred to, and stored at a destination outside of the EEA for purposes described above (including, Canada, Israel and the United States). The recipients may be located in countries which do not provide a similar or adequate level of protection to that provided by countries in the EEA.

If we transfer Personal Data of individuals located in the European Union or EEA to entities within our organization located outside of the EEA, we will do so in compliance with lawful mechanisms, which may include the standard contractual clauses ("Model Clauses") adopted by the European Commission. .

Transfers to service providers and other third parties will comply with applicable data protection laws.

The Service is hosted in the United States. By accessing the Service, you hereby expressly consent to the transfer of your Personal Data to PATTERN in the United States.

We may also transfer your Personal Data outside of the EEA when required by law (e.g., if we receive a valid and mandatory request from a judicial, regulatory or law enforcement body that carries the force and effect of law). Such transfers will be made in accordance with applicable privacy data protection laws.

  1. Security

We maintain reasonable security measures in place to protect Personal Data from accidental loss, or use and protect against unauthorized access. We limit access to your Personal Data to those who have a business need to know.

We use various safeguards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

  1. Children

Our Service are not directed to children under the age of 13. We also do not intentionally collect Personal Data from children under the age of 13 through our Service. If you are the parent or guardian of a child under the age of 13, and you believe that we have inadvertently received Personal Data about your child, please contact us as described in the How to Contact Us section of this Privacy Policy to delete the Personal Data.

  1. Changes to this Privacy Notice

This Privacy Policy may be updated periodically to reflect changes in our privacy practices or relevant laws and will indicate when it was last updated. Please review this policy every time you access or use our Service to make sure that you have reviewed the most recent version.

  1. How to Contact Us

If you have any questions or comments about this Privacy Policy, if you need to report a problem, or if you are located in the EU and would like to exercise your rights under EU law data protection law, please contact our privacy team via email, or at PATTERN Beauty, LLC, 2210 E Maple Ave, El Segundo, CA 90245 USA, Attn: Privacy.

  1. California Residents: Your California Privacy Rights.

California residents have the right to request the identity of any third parties to whom the resident’s personal information was shared, if such sharing was to enable the third party’s direct marketing efforts. If you are a California resident and wish to make such a request, please submit your request to hello@patternbeauty.com OR to opt-out of having your personal information shared with third parties for their direct marketing purposes, please email us at hello@patternbeauty.com .

To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response.  You must include your full name, email address, and postal address in your request.