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Privacy Policy - Clients (Makeup Recipients)

1.

Part A Introduction

1.1.

Identity of the Operator

This Privacy Policy (“Policy”) is issued by MyMkUp 2024, LLC, (the “Operator”), which owns and operates the mobile and web application (the “Application”). The Operator is committed to protecting the privacy and personal data of all users of the Application who register as makeup consultation recipients (“Clients”).

1.2.

Purpose of the Policy

The purpose of this Policy is to provide Clients with clear and transparent information regarding the collection, use, storage, and disclosure of their personal data, in accordance with applicable privacy and data protection laws.

1.3.

Scope

This Policy applies solely to Clients of the Application. A separate privacy policy applies to Makeup Artists who use the Application.

1.4.

Acceptance of the Policy

By registering for, accessing, or using the Application, the Client acknowledges that she/ he read and understood this Policy, and agrees to the collection, use, storage, and disclosure of the personal data in accordance with its terms.

2.

Part B Types of Information Collected

The Operator may collect and process the following categories of personal data relating to Clients:

2.1.

Registration Information

Full name, mobile phone number, email address, password, and, where applicable, login credentials obtained through Google or Facebook (Single Sign-On).

2.2.

Session Information

Video and audio recordings of makeup consultation sessions conducted through the Application, which may include the Client’s image, voice, and any other personal data disclosed during the session.

2.3.

In-App Communications

Messages, chat logs, and other communications exchanged between Clients and Makeup Artists through the Application’s dedicated chat feature.

2.4.

Technical and Usage Information

Device identifiers, IP address, browser type, operating system, log files, cookies, and other technical data regarding the Client’s interaction with the Application.

2.5.

Booking and Transaction Records

Details of bookings and payments made through the Application, including service type, date, and amount. For clarity, the Operator does not store Clients’ credit card details; all payment processing is handled by certified third-party providers.

3.

Part C Use of Information

The Operator may use the information collected from Clients for the following purposes:

3.1.

Provision of Services

To operate, administer, and provide the functionalities of the Application, including enabling communication, scheduling, and delivery of sessions with Makeup Artists.

3.2.

Bookings and Communications

To process bookings, send confirmations, reminders, and other service-related messages that are necessary for the performance of the services.

3.3.

Service Improvement and Complaint Handling

To monitor usage, analyze performance, and review session recordings for the purpose of improving the Application, ensuring service quality, and handling complaints or disputes.

3.4.

Session Recordings

All sessions conducted through the Application may be recorded and securely stored by the Operator. Such recordings are used for quality assurance, training, and complaint resolution. Clients may be offered the option to purchase access to the recording of their own session for a fee.

3.5.

Artificial Intelligence (AI) Development

With the Client’s explicit and informed consent, session recordings may also be used, in whole or in part, for the development, training, and improvement of artificial intelligence (AI) tools and technologies. The Client hereby provides explicit and informed consent to such use, and acknowledges that providing this consent is a mandatory condition for the use of the Application. Refusal to provide or maintain this consent shall immediately prohibit the Client from using the Application or any of its services.

3.6.

Marketing and Promotional Communications

With the Client’s consent, the Operator may send promotional messages, including offers of products and services (including third-party products). The Client may withdraw her/ himconsent at any time without affecting the use of the Application.

3.7.

Legal Compliance

To comply with applicable laws, regulations, legal processes, and governmental requests, and to enforce the Operator’s rights under the Terms of Use.

4.

Part D Information Sharing

The Operator may share Clients’ personal data in the following circumstances and only to the extent necessary:

4.1.

With Makeup Artists

Certain basic information, such as the Client’s name and booking details, will be shared with the selected Makeup Artist for the purpose of conducting the booked session.

4.2.

With Service Providers

With trusted third-party service providers engaged by the Operator to perform functions on its behalf, including IT and hosting services, data storage, analytics, customer support, and payment processing. These providers are authorized to process data only as necessary to provide their services and are bound by confidentiality and data protection obligations.

4.3.

With Authorities and Legal Proceedings

With courts, law enforcement agencies, regulators, or governmental authorities, if and to the extent required by applicable law, regulation, legal process, or enforceable governmental request, or if disclosure is reasonably necessary to protect the Operator’s rights or prevent fraud or security issues.

4.4.

Corporate Transactions

In connection with, or during negotiations of, any merger, acquisition, reorganization, sale of assets, or financing of the Operator.

4.5.

No Sale of Data

The Operator does not sell, rent, or trade Clients’ personal data to third parties for their own commercial purposes without the Client’s explicit consent.

5.

Part E Data Retention and Security

5.1.

Retention Periods

The Operator shall retain Clients’ personal data only for as long as necessary to fulfill the purposes set out in this Policy or as required by applicable law. Session recordings and related data may be stored for extended periods where needed for quality assurance, complaint resolution, or, with the Client’s consent, for AI development.

5.2.

Deletion of Data

Upon termination of a Client’s account or upon request, the Operator shall delete or anonymize personal data within a reasonable time, unless retention is required by law or necessary for legitimate business purposes such as dispute resolution, fraud prevention, or enforcement of rights.

5.3.

Security Measures

The Operator implements appropriate technical and organizational measures to safeguard personal data against unauthorized access, accidental loss, misuse, alteration, or disclosure. Such measures may include encryption, access controls, monitoring, and regular security assessments.

5.4.

Limitations

While the Operator takes reasonable steps to protect Clients’ information, absolute security cannot be guaranteed against all cyber threats, unauthorized access, or system failures. Clients acknowledge that they provide information at their own risk.

6.

Part F Rights of Clients

Subject to applicable law, Clients have the following rights with respect to their personal data:

6.1.

Right of Access

To obtain confirmation as to whether the Operator holds personal data about them and to request a copy of such data.

6.2.

Right of Rectification

To request correction or updating of inaccurate, incomplete, or outdated personal data.

6.3.

Right of Erasure (Right to be Forgotten)

To request deletion of personal data where it is no longer necessary for the purposes for which it was collected, or where consent has been withdrawn (where applicable), subject to legal or contractual retention obligations.

6.4.

Right to Restrict Processing

To request that the Operator limit the processing of their personal data in certain circumstances, such as where the accuracy of the data is contested.

6.5.

Right to Object

To object, on legitimate grounds, to the processing of personal data, including for direct marketing purposes.

6.6.

Right to Data Portability

Where technically feasible, to request receipt of their personal data in a structured, commonly used, and machine-readable format, and to request transfer of such data to another controller.

6.7.

Right to Refuse Consent for AI Use

Clients are under no legal obligation to consent to the use of their session recordings for AI-related purposes. However, the Client acknowledges and agrees that providing such consent is a mandatory condition for the use of the Application, and that refusal to provide or maintain this consent shall prevent the Client from using the Application.

6.8.

How to Exercise Rights

To exercise any of the rights described above, Clients may contact the Operator using the contact details provided in Part H of this Policy. The Operator may require verification of identity before fulfilling such requests.

7.

Part G Cookies and Similar Technologies

7.1.

Use of Cookies

The Application and related websites may use cookies and similar technologies (such as web beacons, pixels, and local storage) to enable the functionality of the Application, enhance user experience, analyze usage patterns, and deliver relevant content.

7.2.

Types of Cookies

i.

Essential Cookies – required for the core operation of the Application, including login, authentication, and payment processing.

ii.

Performance and Analytics Cookies – collect information about how Clients use the Application to help improve functionality and performance.

iii.

Functionality Cookies – store preferences such as language, display settings, and saved options to personalize the experience.

iv.

Marketing Cookies – used, with the Client’s consent, to deliver personalized offers, promotions, and advertisements.

7.3.

Managing Cookies

Most web browsers allow Clients to control cookies through their settings, including blocking or deleting them. Please note that disabling certain cookies may limit the functionality or performance of the Application.

7.4.

Third-Party Cookies

The Operator may permit trusted third parties, such as analytics providers or payment processors, to place cookies or similar technologies within the Application. These third parties may collect information directly from Clients’ devices in accordance with their own privacy policies.

8.

Part H Miscellaneous

8.1.

Changes to this Policy

The Operator may amend or update this Privacy Policy from time to time at its sole discretion. Any changes will be posted within the Application and/or on the Operator’s website, and the “last updated” date will be revised accordingly. Continued use of the Application after such posting shall constitute the Client’s acceptance of the updated Policy

8.2.

Governing Law and Jurisdiction

This Policy shall be governed by and construed in accordance with the laws of the State of Israel, without regard to conflict of laws principles. The courts of Tel Aviv-Jaffa shall have exclusive jurisdiction over any dispute arising out of or in connection with this Policy.

8.3.

Contact Information

For any questions, requests, or complaints regarding this Privacy Policy or the processing of personal data, Clients may contact the Operator at:

Email: Info@MyMkUp.com