Purpose
The purpose of the collection, storage, processing, and use of personal information for Shade Finder is to provide You with a meaningful, efficient way to evaluate products for potential purchase and use. When You use L’Oréal Paris’ Shade Finder, L’Oréal Paris collects and processes certain data, see “How It Works,” infra, in order to deliver a better beauty experience to You. L’Oréal Paris may use information about You to communicate with You about L’Oréal Paris ’s beauty products and services; answer questions; create better experiences; provide tailored advertising, content, services, recommendations, and communications; fulfill product purchases and process payments; analyze use of L’Oréal Paris ’s products and services, without any associated personal identification information of users, so as to improve effectiveness of L’Oréal Paris ’s Site, customer service, and offerings, including improvement of the virtual Shade Finder tool and underlying algorithm; conduct research, including high-level analytics without associated personal identification information; to comply with applicable laws or legal obligations; and TO ENFORCE THE TERMS OF USE, which additionally govern and apply to Your use of Shade Finder.
How It Works
In order to use Shade Finder You must upload a video selfie of Yourself. Your video selfie will be transmitted from your device to a central cloud-based hub, where it is broken down into frames. L’Oréal Paris will use an algorithm to analyze the video selfie to detect face landmarks to localize the region around key facial features (i.e., outline of eyes, lower part of nose, outline of lips, etc.). This information is used to center, zoom, crop, and remove unnecessary features from the image(s) (such as eyes, nose, and mouth).]
L’Oréal Paris will use an additional algorithm to analyze the frames to calculate an estimate of Your skin tone. By analyzing multiple frames from the video You uploaded, the algorithm will take an average of the values and match it to a model. This information is used to provide you with recommendations. You will then be provided with Your results and suggested product(s).
Your Consent For Collection and Use of Your Personal Information
When You use Shade Finder, you specifically consent that:
- L’Oréal Paris is collecting, capturing, possessing, storing, or obtaining the picture You provide, and data obtained or created from Your picture (including the automated recognition of various facial landmarks), that might qualify as biometric data, biometric information, or a biometric identifier under various laws.
- L’Oréal Paris may share, disclose, or disseminate information about You with any other affiliated company or brand as well as its service providers.
When you consent to “EMAIL MY RESULTS”, You also agree to the storage or retention of personal information about you, including information derived from Your Image. Specifically, you consent that:
- L’Oréal Paris will store personal information about You as described in our Privacy Policy, which will be retained subject to limitations in our Privacy Policy.]
YOU UNDERSTAND THAT YOUR CONSENT TO THIS INFORMATION NOTICE IS A PREREQUISITE TO USE OF SHADE FINDER.
L’Oréal Paris’ Shade Finder Information Notice coexists with, supplements, and does not supplant, obviate, replace, or otherwise supersede or suspend any other policy applicable to Your use of L’Oréal Paris ’s website and Shade Finder, including the Terms of Use and Privacy Policy.
L’Oréal Paris’ Shade Finder Information Notice is subject to periodic updating, including to the extent that L’Oréal Paris begins collecting personal information for any other purposes not specified herein. L’Oréal Paris reserves the right to amend this policy at any time, which amendments will further apply to Your use of Shade Finder after their enactment.
Data Retention
L’Oréal Paris only briefly stores your selfie. Once the information is returned to You, Your selfie is deleted from the central cloud-based hub (generally within a matter of seconds of completion of the analysis).
The coordinates of facial landmarks, the results from analysis used to calculate Your skin tone, and all recommendations provided to You are stored in the central cloud hub to help L’Oréal Paris and its Affiliates improve its Products and its users’ experiences. This data will be stored only as long as needed for L’Oréal Paris and its Affiliate’s business purposes and, in any event, no longer than 3 years after our last interaction with You.
Email Marketing
If You voluntarily provide L’Oréal Paris with Your name and contact information, or You sign up to receive promotional messages from L’Oréal Paris, the identified skin tone/undertone and product recommendations are stored within Your profile at L’Oréal Paris. To sign-up, you will need to provide Your name and email information (hereinafter, ‘contact information’) to L’Oréal Paris. If you provide L’Oréal Paris with Your name and contact information, the identified skin tone and product recommendations provided to You will be retained by L’Oréal Paris in accordance with L’Oréal Paris’s record retention and privacy policies and in accordance with applicable law. For residents of Illinois, we will only store information derived from the analysis of Your selfie (i.e., Your skin results) as long as needed by L’Oréal Paris and in any event no longer than 3 years from the date of our last interaction with You.
Right of Deletion
Depending on your location, You may have the right under the law of your state of residence to request deletion of, data about you at any time. In order to so indicate, You shall submit the request using the methods outlined in L’Oréal Paris’ Privacy Policy.
If You request deletion of data about you, You understand and acknowledge that L’Oréal Paris will keep a log of Your doing so, which log will include information such as Your name, date of request, manner of request, and date of fulfillment:
PLEASE NOTE that should You request deletion of data about You at a time when L’Oréal Paris is compelled by law or order of court of competent jurisdiction to maintain such data, L’Oréal Paris will not immediately comply with Your deletion request.
Data Storage
L’Oréal Paris uses a reasonable standard of care to store, transmit, and protect from disclosure any data used in Shade Finder consistent with the sensitivity of the data. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure.
Disclosure
L’Oréal Paris may share, disclose, or disseminate personal information with any other affiliated company or brand. L’Oréal Paris will also disclose personal information to L’Oréal Paris ’s service providers who help L’Oréal Paris provide You with services. L’Oréal Paris may also disclose personal information to comply with federal or state law, local law, municipal ordinance, or court order, including in connection with a validly issued warrant or subpoena.
