Privacy Policy

Last Updated: May 29, 2024

SUMMARY

At Flawless Future Foundation, we take your privacy seriously and want you to be informed about our practices and procedures when it comes to your personal data. We collect personal data about you on different occasions, such as when you browse or submit information on our website at https://ww.flawlessfuturefoundation.com (the “Website”), use our mobile app (the “App”), or perform a skin scan. This Privacy Policy, which is incorporated by reference into our Terms of Service, outlines how and when we collect, use, and share personal data. 

WHO WE ARE

The terms “FFF,” “we,” “us,” and “our” are used in this Privacy Policy to refer, collectively, to Radiant Reach, 1942 Broadway Street Ste 314C, Boulder, CO 80302.

THIRD PARTIES

“Third Parties” include any person or entity other than you and our related companies and employees. Third Parties include, but are not limited to, government agencies, our marketing partners, the suppliers, service providers, and other vendors that help us run our Website and App.   The Website and/or App may include links to Third Party sites, services, and apps.

Unless otherwise expressly stated, this Privacy Policy does not apply to any Third-Party practices, websites, mobile apps, or services. Third Parties may have their own privacy practices and policies, which you should review before engaging with their platforms and services.

OUR COLLECTION OF PERSONAL DATA

How We Collect Personal Data

We collect personal data directly from you at various points during your use of our Website and/or App.  We primary collect personal data when you engage with us, whether through the Website, App, in person, or other means, such as:

·       When you browse or complete a form on the Website or App;

·       When you submit photos, videos, or other image or audio files to us through the Website or App;

·       When you click on a link in an FFF advertisement;

·       When you complete a “Skin Scan” on the Website or App;

·       When you make payments to us;

·       When you communicate with us, such as by speaking to one of our customer service agents;

·       When you post content to the Website or App, such as a review (“your Content”);

·       When you sign up to receive email, text/SMS, or other communications from us;

·       When you participate in a survey, contest, or sweepstakes administered by FFF; and

·       When you apply for a job with us.

Like most websites and apps, we collect data through automated technologies on our Website and App, such as cookies, web beacons and pixels. These practices are discussed more fully in the section below entitled Cookies and Other Data Technologies.

Categories of Personal Data Collected

Through the methods identified herein, we collect the following categories of personal data:

Identifiers

We collect basic contact information, such as name, address, phone number, mobile number, email address, age, and gender. 

We may also collect account information, such as your username and password for the Website or App.

Commercial Data

We may collect transaction information, such as details about your Skin Scan and the results thereof, and other products and services you have purchased or considered, and your purchasing tendencies.

We collect financial information, such as name, bank account number, credit or debit card number, billing address, and payment history.

We may collect or create inferences, such as creating a consumer profile for you or a group of customers relating to consumer preferences and trends.     

Personal Background

We collect employment information when you apply for a job with the FFF Group, including your contact information, government-issued identification, professional licenses and credentials, union membership, employment history, educational background, citizenship and immigration status, military service, and references. 

Audio and Visual Data

We collect audio and visual data, such as photographs, audio and video recordings, when you voluntarily submit the same to us through the Website or App, such as when you complete a Skin Scan.

Communications

We collect any information you communicate to us, such to our customer service agents, or via a feedback form, regardless of whether it fits into one of the other categories of personal data outlined herein. Such information is volunteered by you and we do not collect it surreptitiously.

When you communicate with us via any live chat feature on our Website or App, your live chat transcripts may be monitored or reviewed by the Third-Party live chat service provider. 

Geolocation

We collect general geolocation data from users of the Website or App by ascertaining approximate location (e.g., city or country) from the user’s IP address.

Other Personalized Data

We may collect other personalized data on a case-by-case basis, but only when you expressly consent to the same before it is collected. 

Non-Personalized Data

We collect device, internet, and network data, such as the type of device (e.g., computer, smart phone, tablet), device ID, MAC address, mobile carrier, phone number, operating system, IP address, internet service provider, browser language, browsing history, search history, advertising ID, and any other information regarding your interaction with the Website, App, or an FFF advertisement. See below for more information about cookies and other tracking technologies.

We may collect or create aggregate information or de-identified data from the personal data collected. For example, we may combine the personal data of multiple users of the Website or App to create data that no longer identifies the users on an individual basis but speaks to behavioral or consuming patterns. If we combine aggregate information or de-identified data with personal data, we will treat it as personal data in accordance with the provisions of this Privacy Policy.

OUR USE OF PERSONAL DATA

We use personal data for the same reasons that we collect it.  Specifically, we process personal data for the following purposes:

SENSITIVE PERSONAL DATA

Certain categories of personal data collected—such as financial account information—may qualify as “Sensitive Personal data” under applicable law.

Limited Purposes

We only collect and use Sensitive Personal Data when reasonably necessary for and proportionate to one of the following business purposes: (a) to perform certain services, such as verifying information or for analytics; (b) to verify or maintain the quality or safety of our services, including our Website, and App; (c) to perform services reasonably expected by you; (d) for short-term use where there is no disclosure or profiling; and/or (e) to resist malicious, fraudulent, or illegal actions or to ensure physical safety. 

Our Retention Policy for Sensitive Data

Sensitive Personal Data will be retained in compliance with any legislation governing the retention and deletion of such data.

Data Security

We employ industry-standard security measures to protect the Sensitive Personal Data we collect, including encryption, access controls, and regular security assessments to prevent unauthorized access, disclosure, or alteration of the data.

DISCLOSURE OF PERSONAL DATA TO OTHERS

As part of our business, we disclose information to Third Parties as follows and for the outlined purposes, which include business purposes to provide our Skin Scan services, the Website, the App, and related service and to comply with legal and contractual obligations, as well as commercial purposes, such as to promote our Skin Scans and other offerings.

Our Affiliated Entities

We may disclose your personal information to other companies that are under common ownership with us. In such event, our affiliated entities will treat your personal information in compliance with this Privacy Policy. However, if you visit the website, purchase a product, or otherwise transact business directly with one of our affiliated entities, then any information collected by the affiliated entity from you during that transaction will be subject to the terms of the affiliated entity’s privacy policy. 

Service Providers and Contractors

Some services that you obtain through us are provided by Third-Party service providers and contractors. We may need to communicate your name to such partners in order to provide you with the service you requested. Accordingly, such disclosure is for business purposes, including to provide you with services that you have requested, and for commercial purposes, such as to advertise our Skin Scans and related services to you and others. 

These Third-Party service providers and contractors operate in several industries, including the following:

• Advertising (e.g., social media, web, streaming, and broadcast television platforms);

• Skincare Companies (e.g., providers of serums, creams, moisturizers, and other skin care products);

• Payment processors (e.g., banks and other financial institutions that collect payments); and

• Software and technology (e.g., providers of hosting, security, email, and live chat services for the Website and App, and the provider of the Technogym technology in our fitness centers).

When we provide your personal data to Third-Party service providers and contractors, we only communicate data that is strictly necessary. We also have agreements in place with our Third-Party service providers and contractors to ensure that the data we communicate to them is used only for specific purposes related to the fulfilment of your request.

Legal Process and Protection

We may disclose information as necessary to comply with our legal obligations, such as to respond to government requests, law enforcement inquiries, legal processes, subpoenas, and court orders.

We may disclose information when we believe it is necessary to investigate, prevent, or respond to illegal, fraudulent, or injurious actions or security incidents that may cause harm to us, our Website, App, and/or others. We may also disclose information in good faith where necessary to investigate or enforce a violation of this Privacy Policy, our terms, or any legal rights.

Merger or Sale

We may share information with a buyer and/or its representatives for business purposes as part of a sale, merger, acquisition, or other change in control or entity status, either in whole or in part, of any company within the FFF Group. We reserve the right to transfer or assign your information as part of any such transaction or investigation.

Consent

We may disclose information to Third Parties as requested or consented to by you. Such disclosure may be for any business or commercial purpose as described by you.

COOKIES AND OTHER DATA TECHNOLOGIES

Use of Data and Tracking Technologies and the Website and App

As with many companies, we may use cookies, pixels, gifs, web beacons, log files, and/or similar technologies to automatically collect certain information, including device, internet, and network data, general geolocation data, inferences, and aggregate information or de-identified data, when you use the Website or App or interact with our digital advertising content, such as when you click on an FFF advertisement or a link to the Website within an email. This allows us to track individual users, determine when content is accessed, and customize user experiences.

Unless you have opted out of cookies or changed your cookie settings in your internet browser, your browser automatically sends us certain device, browser, internet connection, and general geolocation information and certain internet activity information. For instance, we may collect your mobile device identifier or MAC address, ISP carrier information, date and time you access the Service, the pages you visit, and whether you click on ads.

Cookies

Cookies are small text files sent by websites to users’ browsers for the purpose of automatic authentication, session tracking and storing of specific information regarding users. There are essentially three types of cookies used on the Website and/or App:

“Technical cookies” are required for navigation within the Website or App and to use some of its functions (e.g. timing the display of certain pages in so-called “pop-up” mode etc.).

“Statistical cookies” (e.g., Google Analytics) are supplied and managed by Google to provide a statistical analysis of access to the Website. The data collected is Non-Personalized Data, is solely collected anonymously and in aggregate form, and no personal user data is retained. You can decide not to use Google Analytics cookies by following the instructions at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

“Profiling cookies” are supplied and managed by Third Parties to generate specific advertising messages based on browsing habits and the interests of individual users. These cookies do not, however, use Sensitive Personal Data. The Website currently uses the Google Doubleclick cookie. For more information, including information to opt out from the cookie, please click the following link: https://policies.google.com/technologies/ads?hl=en-GB. Please see below for more information on personalized advertising.

You can change your cookie settings in your internet browser and use settings on your device to manage your privacy controls. For more information and ways to opt out, see https://www.allaboutcookies.org/, and learn how to disable these tools by opting-out of third-party cookies and mobile device ID practices. 

Please note that disabling cookies may impair the correct functioning of certain Website features.

Pixels

Pixels are small pieces of code embedded on a website that allow website owners and third parties to track user behavior and gather information about how users interact with the website. Pixels can track actions like page views, clicks, and other related activities and are often used for Personalized Ads and website analytics.

We may use pixels on the Website and App to associate personal data with your device or IP address and to track and measure your engagement with the Website, App, and Personalized Ads. For example, the Website and App may utilize Meta Pixel and/or the TikTok Advertising Pixel, which allow us to track and analyze the effectiveness of our advertising campaigns on Facebook, Instagram, and TikTok. These pixels enable us to measure the success of our advertisements by understanding the actions users take on our Website or App after viewing our Facebook, Instagram, and TikTok ads. The data collected through such pixels may be used for marketing and analytical purposes to enhance our understanding of user preferences and to improve our advertising strategies. You can manage pixel data sharing settings within the Settings section of your Facebook, Instagram, and TikTok accounts.

MARKETING

Personalized Advertising

We may work with Third-Party advertising companies to process personal data (but not Sensitive Personal Data) for the commercial purpose of displaying ads tailored to your individual interests based on your online and transactional activity and to provide ad-related services such as analytics and market research (collectively, “Personalized Ads”). Third parties, in turn, may use a cookie, web beacon, pixel or other similar technology to collect personal data from you and/or associate it with other personal data collected.

We may also send you Personalized Ads in the form of email, phone, and SMS/text communications and newsletters tailored to your preferences and purchasing tendencies.

Other Marketing Communications

When you provide us your email address via the Website or App, you will receive emails about your account, Skin Scan, product recommendations, and related services that may include non-personalized marketing messages. These messages may come from us or our affiliated entities.

Similarly, when you provide us your phone number and consent to receive calls or SMS/text messages, you may receive non-personalized marketing communications.

Revoking Consent

To opt-out of cross-device linking and Personalized Ads, visit www.aboutads.info/choices or perform a global opt-out on each browser and device.

You can opt-out of receiving Personalized Ads and other marketing communications by email by clicking the unsubscribe link and following any subsequent instructions. 

You can opt-out of receiving Personalized Ads and other marketing communications by SMS/text message by replying STOP.

You can opt-out of receiving Personalized Ads and other marketing communications by phone by asking to be placed on FFF’s internal Do Not Call list. 

To opt-out of Personalized Ads and other marketing communications and notifications on Third-Party platforms, such as Meta (Facebook, Instagram), TikTok, Google, Android, and iOS, you can change your user settings on such platforms.

Please note that we may still contact you regarding your Skin Scans and other transactions, even after you have opted out of marketing communications.  For example, if you unsubscribe from marketing emails and subsequently complete a Skin Scan, we will still email you recommendations specific to your Skin Scan. 

SALE OF PERSONAL DATA

FFF does not sell personal data.

As discussed above, FFF participates in targeted advertising or Personalized Ads, which is also called interest-based or online behavioral advertising and may include cross-contextual advertising.  Under some privacy legislation, Personalized Ads may constitute the “sale” or “sharing” of personal data, such as for business purposes (e.g., providing our Skin Scans and related services) and commercial purposes (e.g., marketing). To opt out of these practices, please see the section above about revoking consent or visit our Do Not Sell or Share My Personal Information page.

FINANCIAL INCENTIVES

We may offer incentives related to the collection, retention, or sharing of information that may be deemed a “financial incentive” or “price or service difference.” If you opt in to such an offering pursuant to the terms described at the time of signup, we may collect information such as contact information, transactional information and inferences, internet or other network activity, and device information. Any difference in price or rate, such as a discount, will be reasonably related to the value of the data. If you want to withdraw from the offering, please contact us as instructed below.

CHILDREN’S INFORMATION

FFF Group’s privacy practices and this Privacy Policy are designed to comply with the Children's Online Privacy Protection Act (COPPA) and related laws governing the collection, use, disclosure, and retention of the personal data of children. We do not knowingly collect personal information from children under the age of 13. If we become aware that we have collected personal information from children under the age of 13, we will delete the same from our records.

PROTECTION AND RETENTION OF PERSONAL DATA

Our Security Measures

Consistent with others in our industry, we take efforts to employ technical, administrative, and physical security measures for personal data, taking into account reasonable security procedures and accessible technology. However, no system can be completely secure; and we cannot promise, and you should not expect, that your personal data will always remain secure. Your provision of personal data is at your own risk. The safety and security of your information also depends on you. Take steps to safeguard your passwords and other data and notify us as soon as possible if you believe your account security has been breached. We transfer, process, and store data only via reputable and trusted cloud service providers. Our cloud-based data is protected by 256bit encryption or greater. 

Our Data Retention Policy

The personal data that we collect is kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data are collected and processed in each specific case--and in any case, not longer than as specified by the relevant applicable laws. Our internal data retention policy specifies the timeframe for data processing for each category of personal data, at the end of which all copies of the personal data are either destroyed or anonymized using adequate techniques that do not permit the re-identification of the data subject.

TRACKING AND PRIVACY CONTROLS

Our Website does not currently respond to Do Not Track, or “DNT” requests. DNT is a feature that, when enabled, sends a signal to websites to request that your browsing not be tracked.

"GPC” is short for Global Privacy Control settings in your browser or extension. Our Website recognizes GPC signals. This means that if your browser has GPC enabled, our Website will automatically recognize your GPC signal and opt you out of the sale of your personal information, if any. For more information about GPC, please click here: https://globalprivacycontrol.org/.

YOUR PRIVACY RIGHTS

FFF is committed to giving you the appropriate control of your own personal data. Dependent upon the laws of the jurisdiction where you reside, you may have the following rights in connection to your personal data:

• The right to access your personal data and obtain specific information about how we process it. Please be aware that you can only exercise this right in relation to your own data or to the data of a minor or another vulnerable person, where you have provided such data as a holder of parental authority or legal responsibility. FFF reserves the right to ask for proof of identity, as well as to refuse to provide the personal data if the identity or relevant connection to the data subject cannot be proven.

• The right to rectify your personal data, including by means of providing a supplementary statement.

• The right to obtain the deletion of personal data concerning you, subject to certain legal limitations depending upon the laws of your jurisdiction of residence.

• The right to limit or restrict the processing of your personal data, in particular, any Sensitive Personal Data and the use of automated decision making, such as profiling.

• The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or which similarly significantly affects you. Please note that we do not process your personal data using machine learning and/or profiling methods in ways that would impact you in a legal or similarly significant manner.

• The right to opt-out of certain data practices, such as by unsubscribing from marketing communications by following the opt-out instructions in each message or by contacting us as outlined in this Privacy Policy.

• Other Rights. If certain other privacy laws apply to you that provide you with additional rights, please contact us to make a request, as we strive to comply with all privacy rights.

To exercise your data subject rights, please email us at privacy@flawlessfuturefoundation.com or fill out our form at [insert link to privacy request form].

For California Residents

The Shine the Light law permits you to request and obtain from us, once per calendar year, information about any of your personal data shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information and for any other questions about our privacy practices and compliance with California law, please contact us as described below in the section entitled “Contact Us.”

UPDATES

We reserve the right to update, modify, add or remove portions of this information notice at any time. Significant changes to the processing of your personal data will require your approval, in accordance with the applicable legislation. If you would like to obtain a copy of the current or a previous version of the information notice, please contact us using our contact details provided below.

CONTACT US

For any questions regarding this Privacy Policy, please contact us at privacy@flawlessfuturefoundation.com.