Lash Anatomy Information Notice
Lancôme, part of L’Oréal USA, Inc. (collectively, “Lancôme”), has instituted the following Information Notice related to any personal information that Lancôme may obtain, possess, use, process, transfer, or store about you (“You”) because of Your use of Lash Anatomy. For further information about Lancôme’s’ privacy practices as they relate to this service or other personal information Lancôme collects about You when You use our website or other Lancôme services, please review Lancôme PRIVACY POLICY.
Purpose
The purpose of the collection, storage, processing, and use of personal information for Lash Anatomy is to provide You with a meaningful, efficient way to evaluate products for potential purchase and use. When You use Lancôme’s Lash Anatomy, Lancôme collects and processes certain data, see “How It Works,” infra, to deliver a better beauty experience to You. Lancôme may use information about You to (A) communicate with You about Lancôme’s beauty products and services; (B) answer questions; (C) create better experiences; (D) provide tailored advertising, content, services, recommendations, and communications; (E) fulfill product purchases and process payments; (F) analyze use of Lancôme products and services, without any associated personally identifiable information of users, so as to improve effectiveness of Lancôme Site, customer service, and offerings, including improvement of the virtual Lash Anatomy tool and underlying algorithm; (G) conduct research, including high-level analytics without associated personally identifiable information; (H) to comply with applicable laws or legal obligations; (I) for corporate governance, including mergers, acquisitions, divestitures, and other corporate restructurings; and (J) TO ENFORCE THE TERMS OF USE, which additionally govern and apply to Your use of Lash Anatomy.
How It Works
In order to use Lash Anatomy, You must grant a Beauty Advisor permission to take a photograph of Yourself . Your photograph will be transmitted from Your device to a central cloud-based hub, where it is analyzed. Lancôme will use an algorithm to analyze the photograph to detect face landmarks to localize the region around key facial features (i.e., outline of eyes, location of eye lashes, location of your iris , location of the palpebral slit, etc.). This information is used for visualization purposes (i.e., to show you results on the photograph taken) and to provide You with the requested service (e.g., characterize and analyze the eyelashes for the purpose of recommending makeup or mascara). It is not used to identify or verify the identity of any individual.
Lancôme will use additional and separate algorithms to analyze the photograph to isolate and focus on the eyelash (e.g., focus only on portion of image where eyelashes are present to avoid analyzing eyebrows). It will identify and detect eyelash fibers, tips of the eyelashes, and the roots of the eyelashes. The algorithm will analyze the length of the eyelashes by calculating the average distance between the root and tip of detected eyelashes, count the number of eyelashes detected, and calculate the average thickness of eyelashes . These results are assessed and calculated based on average results for the population. For example, eye lashes may be short and sparse, long and sparse, moderately long and moderately dense, short and dense, or long and dense.
Your Consent For Collection and Use of Your Personal Information
When You use Lash Anatomy, you specifically consent that:
• Lancôme is collecting, capturing, possessing, storing, or obtaining the picture You provide or is taken of You by a Beauty Advisor, 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.
• Lancôme may share, disclose, or disseminate information about You with any other affiliated company or brand (including its parent (L’Oreal S.A.) and subsidiaries) as well as its service providers (such as the provider of cloud services used to provide You with the service). Lancôme’s parent company, L’Oreal S.A., will use information as described in this Notice, including for analytics, market research, and to improve the algorithms in order to enhance products and services.
YOU UNDERSTAND THAT YOUR CONSENT TO THIS INFORMATION NOTICE IS A PREREQUISITE TO USE OF LASH ANATOMY.
Lancôme’s Lash Anatomy Information Notice coexists with, supplements, and does not supplant, obviate, replace, or otherwise supersede or suspend any other policy applicable to Your use of Lancôme website and Lash Anatomy, including the TERMS OF USE and PRIVACY POLICY.
Lancôme’s Lash Anatomy Information Notice is subject to periodic updating, including to the extent that Lancôme begins collecting personal information for any other purposes not specified herein. Lancôme reserves the right to amend this policy at any time, which amendments will further apply to Your use of Lash Anatomy subsequent to their enactment.
Data Retention
Lancôme only briefly stores your photograph. Once the information is returned to You, Your photograph is deleted from the central cloud-based hub (generally within a matter of seconds of completion of the analysis). The photograph on the device used to take the photograph is generally deleted after completion of the session but may be retained for up to five (5) days.
The coordinates of facial landmarks, information you provide, measurements made by the algorithm(s), calculations made from such measurements (i.e., short and sparse eyelashes), the results from the analysis provided to You, and all recommendations provided to You are stored in the central cloud hub to help Lancôme and its affiliates (including its parent – L’Oreal S.A. - and subsidiaries) improve its products and its users’ experiences. Coordinates of facial landmarks and information derived from the analysis of Your photograph (i.e., Your results) will be stored only as long as needed for Lancôme and its affiliates’ (including its parent - L’Oreal S.A. - and subsidiaries) business purposes and in any event, no longer than 3 years after our last interaction with You
After completion of the analysis, the scores are sent to the application so the Beauty Advisor may provide you with your results. This information is retained on the mobile application for five (5) days.
Right to Delete
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 Lancôme PRIVACY POLICY.
If You request deletion of data about you, You understand and acknowledge that Lancôme 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 Lancôme is compelled by law or order of court of competent jurisdiction to maintain such data, Lancôme will not immediately comply with Your deletion request. We may also deny a deletion request where otherwise permitted to do so by applicable law.
Data Storage
Lancôme uses a reasonable standard of care to store, transmit, and protect from disclosure any data used in Lash Anatomy consistent with the sensitivity of the data. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure.
Disclosure
Lancôme may share, disclose, or disseminate personal information with any other affiliated company or brand (including its parent and subsidiaries). For example, as disclosed in this Notice, L’Oreal S.A. may access information stored in the central cloud-based hub for analytics, market research, and to improve products and services (including its algorithm) in order to enhance products and services. Lancôme will also disclose personal information to Lancôme’s service providers (including service providers who help Lancôme provide You with services). Lancôme may disclose information in connection with the sale or purchase of our assets, or in connection with any bankruptcy or reorganization proceeding. Lancôme 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 (or other legal process); to verify or enforce our TERMS OF USE or other applicable policies, to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our Sites, or the public.
For more information on Lancôme disclosure practices, or for additional information about rights available to you, please visit our PRIVACY POLICY.
