Community Shade Workshop Privacy Notice
This Community Shade Workshop Privacy Notice (“Workshop Privacy Notice”) explains how your personal information is collected, used, shared, processed, and protected by ROADGET BUSINESS PTE. LTD (“SHEGLAM”) when you participate in SHEGLAM’s in-person Community Shade Workshop (“Workshop”) as well as the rights and choices you have associated with that information. The Workshop Privacy Notice also describes your rights regarding your personal information and explains how you can contact us to learn more about our data practices or to exercise your rights. Your personal information is also subject to SHEGLAM’s Privacy Policy which is incorporated by reference as if fully set forth herein. In the event of any inconsistency or conflict between the Workshop Privacy Notice and SHEGLAM’s Privacy Policy, the terms of this Workshop Privacy Notice shall prevail.
1. What Personal Information Do We Collect?
Personal information is any information that is relatable to an identifiable person. The definition of personal information (used interchangeably in this Workshop Privacy Notice with the term "personal data") depends on where you are located. Personal information does not include data that has been effectively anonymized or aggregated so that it can no longer enable us or others, whether in combination with other information or otherwise, to identify an individual.
We collect personal information from you when you fill out a questionnaire and in-person at our Workshop.
We generally collect the following categories of personal information from you in connection with your participation in our Workshop:
| Categories of Personal Information | |
|---|---|
| Basic Personal Identifiers, such as a name, age, email, and phone number. | Source(s) of information: Manually received directly from you.Purpose(s) of collection/use: All purposes listed in “How Do We Use Your Personal Information?” section below.Retention Criteria: Basic Personal Identifiers will be retained for three years from the date of submission. |
| Communications, such as emails or other exchanges, where SHEGLAM is a party to the communications, including audio recordings where permitted by applicable law. | Source(s) of information: Manually received directly from you.Purpose(s) of collection/use: All purposes listed in “How Do We Use Your Personal Information?” section below.Retention Criteria: Communications will be retained for three years from the date of submission. |
| Content you choose to upload, such as text, images (selfies), along with the metadata associated with the files you upload. | Source(s) of information: Manually received directly from you.Purpose(s) of collection/use: All purposes listed in “How Do We Use Your Personal Information?” section below.Retention Criteria: Uploaded Content will be retained for three years from the date of submission. |
| Preferences, Behavior Data, and Inferences, such as your indicated skin tone, undertone, skin type, cosmetic preferences. | Source(s) of information: Preferences are manually received directly from you, and inferences may be subsequently created by us.Purpose(s) of collection/use: All purposes listed in “How Do We Use Your Personal Information?” section below.Retention Criteria: Preferences, Behavior Data, and Inferences associated will be retained for three years from the date of submission. However, this data may also be anonymized or aggregated and such resulting data may be retained for analytic purposes. |
2. How Do We Use Personal Information?
We use your personal information for the following purposes:
- To verify and facilitate your participation in the Workshop.
- To improve our product or service, or for personalization.
- To undertake marketing, advertising or other promotional activities.
- To comply with legal or compliance requirements.
3. When Do We Share Personal Data?
We may disclose and share your personal information with the parties as described below.
A. Within Our Corporate Organization. SHEGLAM is a corporate organization that has a network of legal entities, business processes, management structures, and technical systems. Where permitted by applicable law, we may share your personal information with our related group companies and, in some cases, other affiliates of our corporate group to provide you with our services, administer our business, provide you with a personalized user experience, or to take actions based on your orders, requests, or preferences.
B. Service Providers. We may provide access to or share your personal information with third-party service providers to facilitate our Workshop, such as Google when using Google Forms and Calendly when scheduling participants’ time.
4. How Does SHEGLAM Secure Your Personal Information?
We maintain reasonable physical, electronic, and procedural safeguards designed to guard your personal data from unauthorized processing, use or disclosure. Our security measures include industry-standard physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information. We also require our service providers to provide privacy and security controls to protect data shared with them in order to perform services.
5. What Are Your Privacy Rights and How to Exercise Them?
Depending on where you live, you may have certain rights regarding your personal information, including, but not limited to:
a. Right to Know/Access/Portability - If you want to access the information we collected or disclosed about you, the business purposes involved and the sources of such information, you can request to receive a copy of your personal data in a structured and machine-readable format. You can submit an access request by sending us an email at data@sheglam.com
b. Right to Correction/Rectification - If you believe that we have incorrect or incomplete information about you, you can submit a correction request by sending us an email at data@sheglam.com
c. Right to be Forgotten/Deletion - You can request that we permanently erase your personal information from our records by sending us an email at sending us an email at data@sheglam.com. However, please note that some data may be retained to the extent it is permitted by applicable law and/or is necessary to comply with our legal obligations (for example, we may retain your order history information to satisfy legally required financial reporting obligations), resolve disputes, or enforce our legal agreements and policies.
d. Right to Opt Out of “Sale”/Sharing/Targeted Advertising - We do not share or sell personal information to third parties therefore we do not provide an opt-out of such sharing or selling of personal information.
e. Requests from Authorized Agents/Third Parties- For the protection of your account and the security of your data, only you or a person you formally authorize to act on your behalf may make a privacy request related to your personal information. If you use an authorized agent to submit such a request, we will require written proof that the authorized agent has been authorized to act on your behalf, which we obtain in the request verification process. Third parties may submit requests on a data subject's behalf; however, requests will still need to be directed to the data subject themselves for verification and authorization to proceed.
f. Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising any of the rights described herein.
g. Lodging Complaints. If you believe we have infringed or violated your privacy rights, please contact us at data@sheglam.com so that we may attempt to resolve any issues to your satisfaction.
h. Automated Decision-Making - Some states grant rights to request that businesses not engage in certain types of automated decision making about you. Because SHEGLAM does not use automated decision making that is subject to this right, we do not accept requests to opt out of automated decision making.
6. Additional Privacy Matters.
i. Third Party Websites - Our Workshop may contain links to third-party sites. This Workshop Privacy Notice does not apply to those third-party sites. We recommend that you read the privacy statements of any other sites that you visit as we are not responsible for the privacy practices of those sites.
j. Children’s Data – In order to participate in the Workshop you must be at least 18 years old. We do not collect personal information from individuals under the age of 18.
k. Transfers of Your Personal Data Outside the US - This Workshop Privacy Notice only applies to residents of the United States. Please note that your personal data may be accessed or transferred outside of the United States, including access from or transfers to our affiliated entities located in China. Such countries may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. For these transfers, we rely on appropriate safeguards as permitted under applicable law and standards. If you do not want your information transferred to, processed, accessed, or maintained outside of the United States, please understand that you may not be able to participate in the Workshop.
7. Contact Us
If you have questions or concerns regarding any information in this Privacy Policy, please contact us at the address listed below or via email to foundation@sheglam.com
Our Privacy Office can also be contacted via our postal address:
SHEGLAM Privacy Office
777 S. Alameda St., Suite 400
Los Angeles, CA 90021