This Privacy Notice for Heather Hill (doing business as Supple) ("we," "us,"or "our"), describes how and why we might access, collect, store, use,and/or share ("process") your personal information when you use ourservices ("Services"), including when you:
Download and use our mobile application (Supple), or any otherapplication of ours that links to this Privacy Notice
Use Supple. Supple is an AI-powered cosmetic skin wellness appthat analyzes facial zones and provides personalized treatments andrecommendations to nearby provider connections
Engage with us in other related ways, including any marketing orevents
Questions or concerns? Reading this Privacy Notice will help youunderstand your privacy rights and choices. We are responsible for makingdecisions about how your personal information is processed. If you do notagree with our policies and practices, please do not use our Services. Ifyou still have any questions or concerns, please contact us [email protected].
This summary provides key points from our Privacy Notice, but youcan find out more details about any of these topics by clicking thelink following each key point or by using our table of contents belowto find the section you are looking for.
What personal information do we process? When you visit, use, ornavigate our Services, we may process personal information depending onhow you interact with us and the Services, the choices you make, and theproducts and features you use. Learn more about personal information youdisclose to us.
Do we process any sensitive personal information? Some of theinformation may be considered "special" or "sensitive" in certainjurisdictions, for example your racial or ethnic origins, sexual orientation,and religious beliefs. We may process sensitive personal information whennecessary with your consent or as otherwise permitted by applicable law.Learn more about sensitive information we process.
Acceptable Use Policy
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Accessibility Statement
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Do we collect any information from third parties? We do not collect anyinformation from third parties.
How do we process your information? We process your information toprovide, improve, and administer our Services, communicate with you, forsecurity and fraud prevention, and to comply with law. We may alsoprocess your information for other purposes with your consent. We processyour information only when we have a valid legal reason to do so. Learnmore about how we process your information.
In what situations and with which parties do we share personalinformation? We may share information in specific situations and withspecific third parties. Learn more about when and with whom we shareyour personal information.
How do we keep your information safe? We have adequateorganizational and technical processes and procedures in place to protectyour personal information. However, no electronic transmission over theinternet or information storage technology can be guaranteed to be 100%secure, so we cannot promise or guarantee that hackers, cybercriminals, orother unauthorized third parties will not be able to defeat our security andimproperly collect, access, steal, or modify your information. Learn moreabout how we keep your information safe.
What are your rights? Depending on where you are locatedgeographically, the applicable privacy law may mean you have certainrights regarding your personal information. Learn more about your privacyrights.
How do you exercise your rights? The easiest way to exercise yourrights is by visiting https://supple.app/privacy, or by contacting us. We willconsider and act upon any request in accordance with applicable dataprotection laws.
Want to learn more about what we do with any information wecollect? Review the Privacy Notice in full.
Personal information you disclose to us
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when youregister on the Services, express an interest in obtaining information aboutus or our products and Services, when you participate in activities on theServices, or otherwise when you contact us.
Personal Information Provided by You. The personal information that wecollect depends on the context of your interactions with us and theServices, the choices you make, and the products and features you use.The personal information we collect may include the following:
email addresses
usernames
passwords
contact or authentication data
Sensitive Information. When necessary, with your consent or asotherwise permitted by applicable law, we process the following categoriesof sensitive information:
biometric data
Payment Data. We may collect data necessary to process your payment ifyou choose to make purchases, such as your payment instrument number,and the security code associated with your payment instrument. Allpayment data is handled and stored by Apple. You may find their privacynotice link(s) here: https://www.apple.com/legal/privacy/.
Application Data. If you use our application(s), we also may collect thefollowing information if you choose to provide us with access or permission:
Geolocation Information. We may request access or permission totrack location-based information from your mobile device, eithercontinuously or while you are using our mobile application(s), toprovide certain location-based services. If you wish to change ouraccess or permissions, you may do so in your device's settings.
Mobile Device Access. We may request access or permission tocertain features from your mobile device, including your mobiledevice's camera, photo library, and other features. If you wish tochange our access or permissions, you may do so in your device'ssettings.
Mobile Device Data. We automatically collect device information(such as your mobile device ID, model, and manufacturer), operatingsystem, version information and system configuration information,device and application identification numbers, browser type andversion, hardware model Internet service provider and/or mobilecarrier, and Internet Protocol (IP) address (or proxy server). If youare using our application(s), we may also collect information aboutthe phone network associated with your mobile device, your mobiledevice’s operating system or platform, the type of mobile device youuse, your mobile device’s unique device ID, and information aboutthe features of our application(s) you accessed.
Push Notifications. We may request to send you push notificationsregarding your account or certain features of the application(s). Ifyou wish to opt out from receiving these types of communications,you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operationof our application(s), for troubleshooting, and for our internal analytics and
reporting purposes.
All personal information that you provide to us must be true, complete, andaccurate, and you must notify us of any changes to such personalinformation.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address
and/or browser and device characteristics — is collected automaticallywhen you visit our Services.
We automatically collect certain information when you visit, use, ornavigate the Services. This information does not reveal your specificidentity (like your name or contact information) but may include device andusage information, such as your IP address, browser and devicecharacteristics, operating system, language preferences, referring URLs,device name, country, location, information about how and when you useour Services, and other technical information. This information is primarilyneeded to maintain the security and operation of our Services, and for ourinternal analytics and reporting purposes.
The information we collect includes:
Location Data. We collect location data such as information aboutyour device's location, which can be either precise or imprecise. Howmuch information we collect depends on the type and settings of thedevice you use to access the Services. For example, we may useGPS and other technologies to collect geolocation data that tells usyour current location (based on your IP address). You can opt out ofallowing us to collect this information either by refusing access to theinformation or by disabling your Location setting on your device.However, if you choose to opt out, you may not be able to usecertain aspects of the Services.
In Short: We process your information to provide, improve, and administer
our Services, communicate with you, for security and fraud prevention, andto comply with law. We may also process your information for otherpurposes with your consent.
We process your personal information for a variety of reasons,depending on how you interact with our Services, including:
To facilitate account creation and authentication and otherwisemanage user accounts. We may process your information so youcan create and log in to your account, as well as keep your accountin working order.
To deliver and facilitate delivery of services to the user. We mayprocess your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We mayprocess your information to respond to your inquiries and solve anypotential issues you might have with the requested service.
To send administrative information to you. We may process yourinformation to send you details about our products and services,changes to our terms and policies, and other similar information.
To fulfill and manage your orders. We may process your
information to fulfill and manage your orders, payments, returns, andexchanges made through the Services.
To request feedback. We may process your information whennecessary to request feedback and to contact you about your use ofour Services.
To protect our Services. We may process your information as partof our efforts to keep our Services safe and secure, including fraudmonitoring and prevention.
To evaluate and improve our Services, products, marketing, andyour experience. We may process your information when webelieve it is necessary to identify usage trends, determine theeffectiveness of our promotional campaigns, and to evaluate andimprove our Services, products, marketing, and your experience.
To identify usage trends. We may process information about howyou use our Services to better understand how they are being usedso we can improve them.
To determine the effectiveness of our marketing andpromotional campaigns. We may process your information tobetter understand how to provide marketing and promotionalcampaigns that are most relevant to you.
To comply with our legal obligations. We may process yourinformation to comply with our legal obligations, respond to legalrequests, and exercise, establish, or defend our legal rights.
In Short: We may share information in specific situations described in this
section and/or with the following third parties.
Vendors, Consultants, and Other Third-Party Service Providers. Wemay share your data with third-party vendors, service providers,contractors, or agents ("third parties") who perform services for us or onour behalf and require access to such information to do that work. We havecontracts in place with our third parties, which are designed to helpsafeguard your personal information. This means that they cannot doanything with your personal information unless we have instructed them todo it. They will also not share your personal information with anyorganization apart from us. They also commit to protect the data they holdon our behalf and to retain it for the period we instruct.
The third parties we may share personal information with are as follows:
AI Service Providers
Perfect Corp (YouCam Skin Analysis API)
Cloud Computing Services
Amazon Web Services (AWS)
Data Backup and Security
AWS S3
Invoice and Billing
Apple (StoreKit payments)
Social Media Sharing and Advertising
Facebook advertising, TikTok and Instagram advertising
User Account Registration and Authentication
Firebase Authentication
Website Hosting
AWS EC2
We also may need to share your personal information in the followingsituations:
Business Transfers. We may share or transfer your information inconnection with, or during negotiations of, any merger, sale ofcompany assets, financing, or acquisition of all or a portion of ourbusiness to another company.
In Short: We offer products, features, or tools powered by artificial
intelligence, machine learning, or similar technologies.
As part of our Services, we offer products, features, or tools powered byartificial intelligence, machine learning, or similar technologies (collectively,"AI Products"). These tools are designed to enhance your experience andprovide you with innovative solutions. The terms in this Privacy Noticegovern your use of the AI Products within our Services.
Use of AI Technologies
We provide the AI Products through third-party service providers ("AIService Providers"), including Perfect Corp (YouCam Skin Analysis API), which processes the facial photo you submit in order to generate cosmetic skin-quality scores. Perfect Corp processes and stores this image on United States-based infrastructure (Amazon Web Services, US) and automatically deletes the image and the analysis results within 24 hours of processing. As outlined in thisPrivacy Notice, your input, output, and personal information will be sharedwith and processed by these AI Service Providers to enable your use of ourAI Products for purposes outlined in "WHEN AND WITH WHOM DO WESHARE YOUR PERSONAL INFORMATION?" You must not use the AIProducts in any way that violates the terms or policies of any AI ServiceProvider.
Our AI Products
Our AI Products are designed for the following functions:
Image analysis
How We Process Your Data Using AI
All personal information processed using our AI Products is handled in linewith our Privacy Notice and our agreement with third parties. This ensureshigh security and safeguards your personal information throughout theprocess, giving you peace of mind about your data's safety.
How to Opt Out
We believe in giving you the power to decide how your data is used. To optout, you can:
Log in to your account settings and update your user account
Contact us using the contact information provided
In Short: This section explains exactly what face data Supple collects, how it is used, shared, and retained, and how you can revoke consent or delete your face data.
Collection, uses, and disclosures. The only face data Supple collects is a facial photograph that you actively choose to submit (using your device's camera or photo library) when you run a skin scan. It is collected only after you grant camera or photo access and accept the in-app Face Data consent screen shown before your first scan. Your facial photograph is used solely to (1) generate your cosmetic skin-wellness scores and estimated cosmetic skin age, and (2) let you view your own past scans in your account. We do not use face data to identify you, and we do not use it for advertising, marketing, profiling, or tracking, and we do not sell it. Face data is disclosed only to the service providers named below and for no other purpose.
Sharing and retention. Your facial photograph is shared only with: (1) Perfect Corp (YouCam Skin Analysis API), our AI Service Provider, which processes and stores the photo on United States-based infrastructure (Amazon Web Services, US) and automatically deletes the photo and the analysis results within 24 hours of processing; and (2) Amazon Web Services (US), where Supple stores your scan photos under your account so you can view your scan history. We retain your scan photos and analysis results only for as long as your account exists.
Deletion and revoking consent. You can revoke your consent to the collection and use of face data at any time by declining or ceasing to run scans, by disabling Supple's camera and photo access in your device Settings, or by contacting us at [email protected]. You can permanently delete all of your face data at any time in the app via Settings > Delete my account, which permanently deletes your account, all stored scan photos, and all analysis results from our systems. You may also request deletion by emailing [email protected].
Third-party protection. We confirm that any third party with whom Supple shares face data — including Perfect Corp (YouCam Skin Analysis API) and Amazon Web Services — is required to provide the same or equal protection of your face data as described in this Privacy Notice.
In Short: We keep your information for as long as necessary to fulfill the
purposes outlined in this Privacy Notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessaryfor the purposes set out in this Privacy Notice, unless a longer retentionperiod is required or permitted by law (such as tax, accounting, or otherlegal requirements). No purpose in this notice will require us keeping yourpersonal information for longer than one (1) months past the termination ofthe user's account.
When we have no ongoing legitimate business need to process yourpersonal information, we will either delete or anonymize such information,or, if this is not possible (for example, because your personal informationhas been stored in backup archives), then we will securely store yourpersonal information and isolate it from any further processing until deletionis possible.
In Short: We aim to protect your personal information through a system of
organizational and technical security measures.
We have implemented appropriate and reasonable technical andorganizational security measures designed to protect the security of anypersonal information we process. However, despite our safeguards andefforts to secure your information, no electronic transmission over theInternet or information storage technology can be guaranteed to be 100%secure, so we cannot promise or guarantee that hackers, cybercriminals, orother unauthorized third parties will not be able to defeat our security andimproperly collect, access, steal, or modify your information. Although wewill do our best to protect your personal information, transmission ofpersonal information to and from our Services is at your own risk. Youshould only access the Services within a secure environment.
Data breach notification. In the event of a data breach in which your personal information — including any facial images or scan data — is lost, accessed, disclosed, or used without authorization, we will notify you and the appropriate authorities in accordance with applicable law. Where we are required to notify you, we will do so without undue delay, for example by email to the address associated with your account, and will describe the nature of the breach, the information affected, and the steps we are taking in response.
In Short: We do not knowingly collect data from or market to children
under 18 years of age.
We do not knowingly collect, solicit data from, or market to children under18 years of age, nor do we knowingly sell such personal information. Byusing the Services, you represent that you are at least 18 or that you arethe parent or guardian of such a minor and consent to such minordependent’s use of the Services. If we learn that personal information fromusers less than 18 years of age has been collected, we will deactivate theaccount and take reasonable measures to promptly delete such data fromour records. If you become aware of any data we may have collected fromchildren under age 18, please contact us at [email protected].
In Short: You may review, change, or terminate your account at any time,
depending on your country, province, or state of residence.
depending on your country, province, or state of residence.
Withdrawing your consent: If we are relying on your consent to processyour personal information, which may be express and/or implied consentdepending on the applicable law, you have the right to withdraw yourconsent at any time. You can withdraw your consent at any time bycontacting us by using the contact details provided in the section "HOWCAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of theprocessing before its withdrawal nor, when applicable law allows, will itaffect the processing of your personal information conducted in reliance onlawful processing grounds other than consent.
Opting out of marketing and promotional communications: You canunsubscribe from our marketing and promotional communications at anytime by clicking on the unsubscribe link in the emails that we send, or bycontacting us using the details provided in the section "HOW CAN YOUCONTACT US ABOUT THIS NOTICE?" below. You will then be removedfrom the marketing lists. However, we may still communicate with you —for example, to send you service-related messages that are necessary forthe administration and use of your account, to respond to service requests,
or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in youraccount or terminate your account, you can:
Log in to your account settings and update your user account.
Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or deleteyour account and information from our active databases. However, we mayretain some information in our files to prevent fraud, troubleshoot problems,assist with any investigations, enforce our legal terms and/or comply withapplicable legal requirements.
If you have questions or comments about your privacy rights, you mayemail us at [email protected].
Most web browsers and some mobile operating systems and mobile
applications include a Do-Not-Track ("DNT") feature or setting you canactivate to signal your privacy preference not to have data about youronline browsing activities monitored and collected. At this stage, no uniformtechnology standard for recognizing and implementing DNT signals hasbeen finalized. As such, we do not currently respond to DNT browsersignals or any other mechanism that automatically communicates yourchoice not to be tracked online. If a standard for online tracking is adoptedthat we must follow in the future, we will inform you about that practice in arevised version of this Privacy Notice.
California law requires us to let you know how we respond to web browserDNT signals. Because there currently is not an industry or legal standardfor recognizing or honoring DNT signals, we do not respond to them at thistime.
In Short: If you are a resident of California, Colorado, Connecticut,
Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota,Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island,Tennessee, Texas, Utah, or Virginia, you may have the right to requestaccess to and receive details about the personal information we maintainabout you and how we have processed it, correct inaccuracies, get a copyof, or delete your personal information. You may also have the right towithdraw your consent to our processing of your personal information.These rights may be limited in some circumstances by applicable law. More
information is provided below.
Categories of Personal Information We Collect
The table below shows the categories of personal information we have
collected in the past twelve (12) months. The table includes illustrativeexamples of each category and does not reflect the personal informationwe collect from you. For a comprehensive inventory of all personalinformation we process, please refer to the section "WHAT INFORMATIONDO WE COLLECT?"
CategoryExamples Collected
A. Identifiers
Contact details, such as real name,alias, postal address, telephone ormobile contact number, uniquepersonal identifier, online identifier,Internet Protocol address, emailaddress, and account name
YES
B. Personal informationas defined in theCalifornia CustomerRecords statute
Name, contact information,education, employment, employmenthistory, and financial informationNO
C. Protectedclassificationcharacteristics understate or federal law
Gender, age, date of birth, race andethnicity, national origin, maritalstatus, and other demographic data
NO
D. Commercialinformation
Transaction information, purchasehistory, financial details, and paymentinformation
YES
E. Biometric informationFingerprints and voiceprintsYES
F. Internet or othersimilar network activity
Browsing history, search history,online behavior, interest data, andinteractions with our and otherwebsites, applications, systems, andadvertisements
NO
G. Geolocation dataDevice location YES
H. Audio, electronic,sensory, or similarinformation
Images and audio, video or callrecordings created in connection withour business activities
YES
I. Professional or
Business contact details in order toprovide you our Services at abusiness level or job title, work
employment-relatedinformationhistory, and professionalqualifications if you apply for a jobwith us
NO
J. Education InformationStudent records and directoryinformation NO
K. Inferences drawnfrom collected personalinformation
Inferences drawn from any of thecollected personal information listedabove to create a profile or summaryabout, for example, an individual’spreferences and characteristics
YES
L. Sensitive personalInformationAccount login information andbiometric data YES
We only collect sensitive personal information, as defined by applicableprivacy laws or the purposes allowed by law or with your consent. Sensitivepersonal information may be used, or disclosed to a service provider orcontractor, for additional, specified purposes. You may have the right tolimit the use or disclosure of your sensitive personal information. We do notcollect or process sensitive personal information for the purpose of inferringcharacteristics about you.
We may also collect other personal information outside of these categoriesthrough instances where you interact with us in person, online, or by phoneor mail in the context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to yourinquiries.
We will use and retain the collected personal information as needed toprovide the Services or for:
Category A - As long as the user has an account with us
Category D - As long as the user has an account with us
Category E - As long as the user has an account with us
Category G - As long as the user has an account with us
Category H - As long as the user has an account with us
Category K - As long as the user has an account with us
Category L - As long as the user has an account with us
Sources of Personal Information
Learn more about the sources of personal information we collect in "WHAT
INFORMATION DO WE COLLECT?"
How We Use and Share Personal Information
Learn more about how we use your personal information in the section,"HOW DO WE PROCESS YOUR INFORMATION?"
Will your information be shared with anyone else?
We may disclose your personal information with our service providerspursuant to a written contract between us and each service provider. Learn
more about how we disclose personal information to in the section, "WHENAND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
We may use your personal information for our own business purposes,such as for undertaking internal research for technological developmentand demonstration. This is not considered to be "selling" of your personalinformation.
We have not sold or shared any personal information to third parties for abusiness or commercial purpose in the preceding twelve (12) months. Wehave disclosed the following categories of personal information to thirdparties for a business or commercial purpose in the preceding twelve (12)months:
The categories of third parties to whom we disclosed personal informationfor a business or commercial purpose can be found under "WHEN ANDWITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
Your Rights
You have rights under certain US state data protection laws. However,
these rights are not absolute, and in certain cases, we may decline yourrequest as permitted by law. These rights include:
Right to know whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request the deletion of your personal data
Right to obtain a copy of the personal data you previously sharedwith us
Right to non-discrimination for exercising your rights
Right to opt out of the processing of your personal data if it is usedfor targeted advertising (or sharing as defined under California’sprivacy law), the sale of personal data, or profiling in furtherance ofdecisions that produce legal or similarly significant effects("profiling")
Depending upon the state where you live, you may also have the followingrights:
Right to access the categories of personal data being processed (aspermitted by applicable law, including the privacy law in Minnesota)
Right to obtain a list of the categories of third parties to which wehave disclosed personal data (as permitted by applicable law,including the privacy law in California, Delaware, and Maryland)
Right to obtain a list of specific third parties to which we havedisclosed personal data (as permitted by applicable law, includingthe privacy law in Minnesota and Oregon)
Right to obtain a list of third parties to which we have sold personaldata (as permitted by applicable law, including the privacy law inConnecticut)
Right to review, understand, question, and depending on where youlive, correct how personal data has been profiled (as permitted byapplicable law, including the privacy law in Connecticut andMinnesota)
Right to limit use and disclosure of sensitive personal data (aspermitted by applicable law, including the privacy law in California)
Right to opt out of the collection of sensitive data and personal datacollected through the operation of a voice or facial recognitionfeature (as permitted by applicable law, including the privacy law inFlorida)
How to Exercise Your Rights
To exercise these rights, you can contact us by visiting
https://supple.app/privacy, by emailing us at [email protected], or byreferring to the contact details at the bottom of this document.
Under certain US state data protection laws, you can designate anauthorized agent to make a request on your behalf. We may deny arequest from an authorized agent that does not submit proof that they havebeen validly authorized to act on your behalf in accordance with applicablelaws.
Request Verification
Upon receiving your request, we will need to verify your identity to
determine you are the same person about whom we have the informationin our system. We will only use personal information provided in yourrequest to verify your identity or authority to make the request. However, ifwe cannot verify your identity from the information already maintained byus, we may request that you provide additional information for the purposes
of verifying your identity and for security or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need tocollect additional information to verify your identity before processing yourrequest and the agent will need to provide a written and signed permission
from you to submit such request on your behalf.
Appeals
Under certain US state data protection laws, if we decline to take action
regarding your request, you may appeal our decision by emailing us [email protected]. We will inform you in writing of any action taken ornot taken in response to the appeal, including a written explanation of thereasons for the decisions. If your appeal is denied, you may submit a
complaint to your state attorney general.
California "Shine The Light" Law
California Civil Code Section 1798.83, also known as the "Shine The Light"
law, permits our users who are California residents to request and obtainfrom us, once a year and free of charge, information about categories ofpersonal information (if any) we disclosed to third parties for directmarketing purposes and the names and addresses of all third parties withwhich we shared personal information in the immediately precedingcalendar year. If you are a California resident and would like to make sucha request, please submit your request in writing to us by using the contactdetails provided in the section "HOW CAN YOU CONTACT US ABOUTTHIS NOTICE?"
In Short: Yes, we will update this notice as necessary to stay compliant
with relevant laws.
with relevant laws.
We may update this Privacy Notice from time to time. The updated versionwill be indicated by an updated "Revised" date at the top of this PrivacyNotice. If we make material changes to this Privacy Notice, we may notifyyou either by prominently posting a notice of such changes or by directlysending you a notification. We encourage you to review this Privacy Noticefrequently to be informed of how we are protecting your information.
If you have questions or comments about this notice, you may email us at
[email protected] or contact us by post at:
Heather Hill2101 Garrison DrLeander, TX 78641United States
You have the right to request access to the personal information we collect
from you, details about how we have processed it, correct inaccuracies, ordelete your personal information. You may also have the right to withdrawyour consent to our processing of your personal information. These rightsmay be limited in some circumstances by applicable law. To request toreview, update, or delete your personal information, please visit:https://supple.app/privacy.