PRIVACY POLICY

INTRODUCTION AND OVERVIEW

This Privacy Policy describes how Rules Beauty LLC d/b/a Half Magic Beauty (“Half Magic Beauty,” “we,” “our,” or “us”) collects, uses, and shares information about you, and applies to your use of any website, mobile application, or online service location that posts a link to this Privacy Policy (each, a “Site”), and all features, content, and other services that we own, control and make available to you (collectively, with the Sites, the “Service”).

WHAT INFORMATION WE COLLECT

We and our agents, vendors, consultants, and other service providers (collectively, “Service Providers”) may collect the following categories of personal information:

* Identifiers, such as your name, address, phone number, IP address, and email;

* Payment information, such as your credit card number, expiration date, card verification number, and billing address if you make a purchase on the Sites;

* Characteristics of protected classifications, such as age, gender, and ethnicity (each of which are completely voluntary and are used mainly to assist us in tailoring product recommendations for you)

* Commercial information, such as which products you browse, add to your cart, buy, or return;

* Internet or other electronic network activity information when you visit the Site or interact with our emails or online ads and content. For example, we use tracking tools like cookies and pixels to automatically collect information like device identifiers, the type of browser and operating system you are using, your browsing and search history on the Site, what areas of the Site you
visit and for how long, what products or content you view and click on, what website you came from to get to us and what website you go to when you leave us, and your interactions with our digital ads and content on other websites. We may also embed web beacons (also known as pixels) in the emails we send to you to help us understand how you interact with those messages, such as whether and when you opened an email or clicked on any content within the email;

* Visual information, such as your eye color, hair color, skin tone, and skin type;

* Professional or employment-related information if you apply for a job, such as your resume/CV, work history, social/professional networking pages, and any other info you choose to submit with your job application; and

* Inferences drawn from any of the above information to create a profile about you.

HOW WE MAY USE YOUR INFORMATION

We may use personal information about you for any purposes consistent with this Privacy Policy or as permitted by applicable law, including to:

* Manage our Site and Services, including your registration and account;

* Process and facilitate your transactions, including purchases made through our online store;

* Customize your browsing and shopping experience on the Site; Respond to your comments, questions, and
requests, and provide customer service;

* Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;

* Prevent and address fraud, breach of policies or terms, and threats or harm;

* Monitor and analyze trends, usage, and activities;

* Conduct research, including focus groups and surveys;

* Improve the Sites, Services, or other Half Magic Beauty applications, marketing efforts, products and services;

* Tailor and serve advertisements to you, and to send you marketing communications regarding our products, services, offers, promotions, rewards and events we think you may be interested in (for information about how to manage these communications and marketing efforts, please see “Your Choices[LL1] ” below);

* Evaluate applications for employment and other employment-related purposes;

* Comply with legal obligations; and

* Fulfill any other purpose disclosed at the time you provide Personal Information.

We will not use information we’ve collected from you for purposes that are materially different, unrelated, or incompatible with this Privacy Policy without providing you with prior notice. Information that has been deidentified or aggregated is not subject to this Privacy Policy, and we and our Service Providers may use it without obligation to you except as prohibited by applicable law.

WE COLLECT INFORMATION ABOUT YOU FROM VARIOUS SOURCES

We collect and receive information about you from various sources, both indirectly and directly:

* Information you provide directly to us. For example, we collect information when you register an account, make a purchase, sign-up for our newsletter, access our content, or otherwise communicate or transact with us through the Service.

* Information collected automatically from your devices. We and our Service Providers use tracking tools like browser cookies, beacons, and pixels to automatically collect information about you when you interact with our Site or Services, including when you view or click on our digital ads and emails that we send to you.

* Information collected on our behalf by Service Providers.  We may hire Service Providers to host or maintain our Site, provide cloud services, send emails, assist with customer support, provide market research or analytics, assist in order fulfillment, collect or publish customer reviews, or process payments, and those Service Providers may collect information about you in providing their services, which they might share with us in certain instances.

* Information provided by our affiliates. We may receive information about you from other brands within the A24 Films LLC ownership structure.

 * Information provided by other parties. We work with other business partners, marketing partners, data brokers, social media platforms, and other Third Party Services (as defined below) that may give us information about you.

HOW WE MAY SHARE OR DISCLOSE YOUR INFORMATION

We may share your information, including personal information, with the following parties:

* With our Service Providers, in order for them to perform the activities listed above in Section 3 above (“How We May Use Your Information”) at our instruction or on our behalf;

* With our affiliates and parent companies. We may share information with other brands within the A24 Films LLC ownership structure.

* With our business partners. For instance, we may share information with other brands with whom we jointly sell or co-brand merchandise, or with whom we run a joint promotion. 

* With marketing companies. We also share information with companies that help us in our marketing efforts, including social media platforms, ad servers, advertising networks, and adtech platforms. This includes allowing select marketing companies to place their own cookies or other tracking tools on our Site to track your activities across time and services, so that they may tailor and serve ads to you based on your activities (“Interest-based Advertising”).  The information collected and stored by these marketing companies remains subject to their own policies and practices. For further information on tracking technologies and your choices regarding them, please see “Your Choices[LL1] ” below;

 * With third parties in relation to the sweepstakes, contests, surveys, and other promotions that we may run from time to time, either by ourselves or jointly with another organization. If you voluntarily choose to enter such a promotion, we may disclose your personal information to third parties for administrative purposes and as required by law (e.g., by publishing your information as part of a legally required winners list, if you win), and we may share your information with a co-sponsor;

* With law enforcement and other parties as required to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements;

* With other parties as reasonably necessary to protect the rights, property, life, health, security and safety of us, the Service or any third party, including to enforce our policies;

* With other companies (including their and our advisors) in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another company;

* With third parties for purposes disclosed at the time you provide your personal information; and

* With third parties at your express consent or at your direction.

Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you, or deidentified information about you, with third parties for any purpose.

Additionally, certain areas of the Service are designed to help you share information with the public and other users, such as public comment sections or other interactive features. If you choose to make information public through our Service, other users will have access to it. We cannot guarantee that the information you make public through our Service will remain protected in accordance with this Privacy Policy. Please think carefully before making information public. You are solely responsible for information you make public.

THIRD PARTY SERVICES, FEATURES, AND DEVICES

Our Service contains content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties (“Third Party Services”), such as social network sites.  In addition, our Service contains features that allow you interact with, connect to, or access our Service through certain Third Party Services and third party devices (“Third Party Features”).  For example, you interact with a Third Party Service when you “like” or “share” content over social media through our Service, or when you purchase merchandise from our online store.  Remember that third parties may use their own tracking tools to independently collect information about you, and may solicit personal information from you. Also, if you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature.

YOUR CHOICES

* Marketing Communications

You can opt out of receiving promotional e-mails from us at any time by following the instructions in the e-mails to click on the unsubscribe link, or by sending an e-mail to us at privacy@halfmagicbeauty.com, with the word UNSUBSCRIBE in the subject field of the e-mail.  Please note that your opt out is limited to the e-mail address used and will not affect subsequent subscriptions or non-promotional communications, such as those about your account, transactions, servicing, or Half Magic Beauty’s ongoing business relations.  You can opt out of receiving text messages from us at any time by responding STOP to any text message we send you. 

* Our "Do Not Track" Policy

  Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is currently no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

* Cookies, Analytics, and Advertising Tracking Tools

As disclosed in Section 2 and Section 4 above, we and our partners automatically collect information about your devices and online interactions using tracking technologies like cookies, pixels, and web beacons, across time and across different platforms.

We use Google Analytics to provide us with information about how you interact with the Service, so that we may customize and improve the Service for you. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

We and our partners may engage in interest-based advertising by using tracking tools to understand your online interactions over time and across different platforms in order to serve advertisements that are more tailored to your interests. To opt-out of tracking for interest-based advertising purposes from participating companies, visit both the Digital Advertising Alliance Web Choices tool at www.aboutads.info/choices and the Network Advertising Initiative opt-out at www.networkadvertising.org/choices/. Please be aware that even if you opt out of interest-based advertising, you will continue to receive online ads. Options you select and choices you make are browser-, website-, and device-specific.  If you clear your cookies, you will need to set your preferences again.

YOUR CALIFORNIA PRIVACY RIGHTS

This Section of our Privacy Policy applies solely to visitors and users who reside in the State of California.

* Shine The Light

California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties for those third parties’ own direct marketing purposes, one time per year.  Half Magic Beauty may share your personal information with third parties for their own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please e-mail us at privacy@halfmagicbeauty.com or send us a letter to Half Magic Beauty (Attn: Legal), 31 W. 27th Street, 11th Floor, New York, NY, 10001. Requests should include “Shine the Light Request” in the email subject line or the first line of the letter, and should include your name, street address, city, state, and ZIP code.

Any California residents under the age of eighteen (18) who have registered to use the Service and who have posted content or information on the Service, can request that such information be removed from the Service by sending an e-mail to privacy@halfmagicbeauty.com. Requests must state that the user personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view.

* California Consumer Privacy Act

The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their personal information. This section describes those CCPA rights and explains how to exercise those rights.

* Your Rights Under the CCPA

Right to Know: You have the right to request that we disclose
certain information to you about our collection and use of your personal information over the past 12 months. You have the right to know: (i) the categories of personal information we collected about you; (ii) the categories of sources for the personal information we collected about you; (iii) the categories of personal information we sold or disclosed, (iv) our business or commercial purpose for collecting and selling that personal information; (v) the categories of third parties with whom we shared your personal information; and (v) the specific pieces of personal information we collected about you over the past 12 months.

Right to Delete: You have the right to request that we delete any of your personal information that we maintain about you, subject to certain exceptions permitted by the CCPA (such as if the information is necessary to complete a transaction or to retain pursuant to legal obligations).

Do Not Sell My Personal Information:  For purposes of this Privacy Policy, “sell” means the sale of your personal information to an outside party for monetary or other valuable consideration, subject to certain exceptions; this could include certain common website practices like allowing a third party to place advertising cookies on our website for purposes of interest-based advertising. Please note that if you would like to opt out of cookie-based tracking for interest-based advertising purposes, you will need to visit http://www.aboutads.info/choices and https://optout.privacyrights.info to opt out of certain uses of cookies for advertising purposes. Your selections are specific to the device, website, and browser you are using. Your selections are also deleted whenever you clear your browser’s cache.

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. We will not discriminate against you for exercising any of your CCPA rights, such as by: (i) denying you goods or services; (ii) charging you a different price or rates for goods or services; or (iii) providing you a different level of quality of goods or service.

* How to Exercise Your Rights Under the CCPA

To exercise your CCPA rights, please submit a verifiable request to us by either emailing us at privacy@halfmagicbeauty.com or sending a letter to Half Magic Beauty (Attn: Privacy), 31 W. 27th Street, 11th Floor, New York, NY, 10001.  

We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps may vary depending on the sensitivity of the personal information and whether you have an account with us. You can designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent.  

Except as otherwise provided by California law, for purposes of CCPA requests, personal information does not include information about Half Magic Beauty job applicants, employees, and other of our personnel, nor does personal information include information about employees and other representatives of third-party entities who do business with.

* Additional CCPA Privacy Disclosures

For purposes of the CCPA, please also note the following specific information about how we collect, use, and share your personal information:

* Depending on our interactions with you, we may collect, use, and disclose for our business and commercial purposes the following categories of personal information set forth in the CCPA: identifiers; payment and customer records information; characteristics of protected classifications under law (such as demographic information like age, gender, and ethnicity); commercial information; professional or employment-related information; internet or other electronic network activity information; education information; visual information (such as your eye color, hair color, skin tone, and skin type); and inferences. See Section 2[LL1]  above for more details.

* We collect and use the above categories of personal information for the business and commercial purposes described in Section 3[LL2] of this Privacy Policy.

* We collect these categories of personal information from the sources described in Section 4[LL3] of this Privacy Policy.

* We may disclose each of these categories of personal information to the categories of third parties as described in Section 5[LL4] of this Privacy Policy.

* We may “sell” the following categories of personal information through our use of advertising cookies: identifiers; commercial information; and internet or other electronic network activity.  We may “sell” to the categories of third parties described in Section 5[LL5] of this Privacy Policy.

NO CHILDREN UNDER 13

The Service is intended for a general audience and not directed to children under thirteen (13) years of age.  Half Magic Beauty does not knowingly collect personal information from children under thirteen (13) years of age. If you are a parent or legal guardian and believe that we have inadvertently received personal information about a child under the age of 13, please email us at privacy@halfmagicbeauty.com.

DATA SECURITY

We take measures designed to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is never completely secure. We cannot guarantee the security of your information collected through our Service.

UNITED STATES ONLY

We are based in the U.S., and the information we and our Service Providers collect is governed by U.S. law. The Service is intended only for users within the U.S., may be accessible globally given the nature of the Internet. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service will be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence, and may not be as protective as those of your country of residence. Your use of the Service or provision of any information constitutes your consent to the transfer to and from, processing, usage, sharing and storage of your information, including personal information, in the U.S. as set forth in this Privacy Policy.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your acknowledgment of the Privacy Policy then posted. If the changes are material, we may provide you additional notice.

CONTACT US

If you have any questions or comments about this Privacy Policy, please e-mail us at privacy@halfmagicbeauty.com or send us a letter to Half Magic Beauty, 31 W. 27th Street, 11th Floor, New York, NY, 10001.