Privacy Policy

In plain words

• What we collect. One frontal face photo that you capture with the guided frame. Optionally, typed details: age, sex, height, and weight. If you join the waitlist, your email address and the role you select. On the website, the usual server logs.
• Why. To produce your own face trend over time and show it to you. That is the purpose.
• What we will not do. We will not sell your face photo, your measurements, or your face trend. We will not use your photo to train models without a separate, specific, opt-in consent. We will not share it with advertisers or data brokers. We do not infer body measurements from the photo and present them as findings.
• Retention. Being finalized. Before any pilot begins, this policy will state exactly how long photos, measurements, and bands are kept and how deletion works. Until then, no photos are stored longer than the pilot agreement allows.
• Your choices. See what we hold, correct it, delete it, withdraw consent at any time. Requests are answered by a person.

Consumer health data, including face-derived measurements, is covered in more detail in our Consumer Health Data Privacy Policy. If the plain words above and the legal text below ever disagree, that is a defect; tell us and we will fix it.

Introduction

VisageAir™ ("VisageAir," "we," "us," or "our") values our relationship with you and takes your privacy seriously. The purpose of this Privacy Policy is to identify how we may process, collect, store, share, and use the data that we collect from you in connection with your access to and use of our wellness application (the "Digital Platform"), as well as our website, visageair.com (the "Website"). This Privacy Policy also describes your rights with respect to your Personal Information. "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

We may update this Privacy Policy at any time by posting the amended version to the Digital Platform or Website. We will announce any material changes to this Privacy Policy via email where we have your address.

How to contact us

You can update your preferences with respect to your information, or ask us anything about this Privacy Policy, by emailing [email protected]. A postal address and telephone number will be published here before any pilot begins.

The information we collect

We collect information from you manually when you provide it to us and automatically when you access or use the Digital Platform or Website. We may collect the following categories of information, depending on your interactions and the choices you make:

Identifiers and technical information (Website)

When you visit the Website, we collect certain electronic information automatically, including your IP address, the type of browser you use, and other information logged by our servers. We use this information to provide, maintain, and improve the Website; to monitor its usage; and to detect, prevent, and address technical issues. We do not run third-party advertising trackers on the Website.

Waitlist and contact information

When you join the waitlist or contact us, we collect the information you provide: your email address, the role you select, and optionally your organization and a message. We use this information to respond to you, to tell you when the pilot opens, and to communicate about VisageAir. You can unsubscribe at any time.

Face photo and wellness inputs (Digital Platform)

When you use the Digital Platform, we collect a single frontal face photo captured with the guided frame and, optionally, typed details such as age, sex, height, and weight. A face photo can identify you and may be treated as biometric information under applicable law. We use this information solely to produce your own face trend over time and a summary of your own change over time, to display the result to you, and to maintain the security and integrity of the Digital Platform. We do not use face photos for advertising or profiling.

Digital Platform usage information

We may collect information about your interactions with the Digital Platform by automated means, including the date and time you use the product, device type, operating system, and technical performance data. We use this information to operate, secure, and improve the Digital Platform and to provide support.

Feedback and correspondence

We may collect the Personal Information you provide when you contact us with questions or feedback. We use it to respond to you and to improve our products and services.

We may use Personal Information to create de-identified and/or aggregated data that is no longer associated with individuals. We process de-identified data only in de-identified form, we will not attempt to re-identify it, and we contractually require any recipient of de-identified data to commit to these same obligations.

Disclosing your information

We may disclose your Personal Information to certain third parties, including under the following circumstances:

• Software and service providers we use to operate the Digital Platform and Website, under contracts that limit their use of your information to providing services to us;
• Law enforcement, government agencies, or other third parties pursuant to legal process or requirements, or to assist a government or law enforcement investigation;
• Our attorneys, consultants, or similar advisors to assess or assert our legal or business interests;
• Other third parties that you expressly request us to share your Personal Information with.

We do not sell Personal Information, and we do not sell, license, or otherwise disclose face photos, face-derived measurements, or face trends to advertisers, data brokers, or affiliates. If we are subject to a merger, acquisition, or similar business transaction, we may transfer information in connection with the transaction, and any successor will be bound by the commitments in this policy.

How we safeguard your Personal Information

We have put in place commercially reasonable security measures designed to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration of your Personal Information. Our standard for any pilot: face photos encrypted in transit and at rest, access limited to the people and systems that need it to produce your result, and every access logged. While we are committed to protecting your Personal Information, information communicated over the Internet is never completely secure, and we cannot guarantee absolute security.

How long we store your Personal Information

Retention periods for face photos, measurements, and bands are being finalized and will be published in this section before any pilot begins. In general, we will retain Personal Information only for as long as is reasonably necessary for the legitimate purposes set out in this Privacy Policy, to comply with our legal, accounting, or reporting obligations, to resolve disputes, and to enforce our agreements. Waitlist information is retained until you unsubscribe or ask us to delete it.

Options regarding your Personal Information

Marketing preferences. You can opt out of receiving communications from us at any time by following the unsubscribe instructions in each message or by contacting us as set out above. Even if you opt out, we may still contact you where necessary to respond to a request you have made.

Consent. Where processing of your face photo is based on your consent, you may withdraw that consent at any time. Withdrawing consent deletes the photo and the measurements derived from it, subject to any retention required by law.

Rights regarding your Personal Information

You may have the following rights ("Data Subject Rights") with respect to the Personal Information that we collect or process about you. Data Subject Rights differ depending on your place of residency, including a number of U.S. states with comprehensive privacy laws. We reserve the right to honor your Data Subject Rights as required by applicable law, including any exceptions allowed to us under applicable law.

• Right to know, access, and obtain a copy. You may ask us to confirm whether we are processing your Personal Information, request details about it, and request a copy.
• Right to amend. If you believe your Personal Information is inaccurate or incomplete, you may request that we correct or complete it.
• Right to delete. You may request that we delete or remove your Personal Information.
• Right to restrict processing. You may ask us to restrict processing of your Personal Information in certain circumstances, including where it is considered sensitive under applicable law.
• Right to opt out of targeted advertising or sharing. We do not engage in targeted advertising and do not "share" Personal Information for cross-context behavioral advertising.
• Right to opt out of sales. We do not sell Personal Information.
• Right to non-discrimination. We will not discriminate against you for exercising these rights.
• Right to appeal. If we deny your request, you may appeal by contacting us and including "Appeal" in your request. You may also be able to contact your state's attorney general.

Only you, or someone legally authorized to act on your behalf, may request to exercise Data Subject Rights. We are required to verify your request and may ask you for information to do so. Submitting a request does not require you to create an account with us. To submit a request, contact us as set out above.

Transfer of data; notice to non-U.S. users

VisageAir is a U.S.-based company, and our infrastructure (including databases and applications that handle and store Personal Information) is hosted in the United States. As a result, it is necessary for us to transfer Personal Information within the United States to provide our services.

Children's information

The Digital Platform and Website are not intended for use by children under the age of 18. By using the Digital Platform or Website, you represent that you are at least 18. If we learn that we have collected Personal Information from a child under 18, we will take reasonable steps to delete it unless we are legally obligated to retain it. If you believe we have collected information from a child under 18, please contact us.

Links to other websites

The Digital Platform or Website may contain links to third-party websites. We have no control over how these websites collect your information and are not responsible for their content, privacy policies, actions, or security.

Updates to this Privacy Policy

We may update this Privacy Policy from time to time and notify you in accordance with law, which may include email or other notice posted to the Digital Platform or Website. When this page changes, the date at the top changes and a short note explains what changed. We will not quietly widen what we collect or how we use it.

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