Opaline Beauty Privacy Policy

Last modified: February 6, 2025

Introduction

Opaline Beauty, Inc. (Company or We) is a technology provider that works with beauty, health, and wellness service businesses (Opaline Customers) to help consumers discover and learn about the treatments they offer.

At Opaline, we believe that wellness and beauty should be for everyone. We respect your rights concerning your personal information and are committed to protecting your rights in compliance with this Privacy Policy.

This policy describes the types of information we may collect from you or that you may provide when you visit our platform opaline.ai (our Service), or when you visit our company website, www.joinopaline.com (our Website).

This Privacy Policy applies to information we collect from the Service and Website, including through desktop and mobile applications that you may have accessed through a link from an Opaline Customer’s website, otherwise been referred to by Opaline Customers, by direct emails to and from us, or through connections via social media log-ins.

This Privacy Policy does not apply to any information you share directly with an Opaline Customer that is not collected by us through our Service or Website.

Please note that by using Opaline’s Service, you may provide personal information that is health-related and, if so, may be protected personal health information or PHI that is subject to special protection requirements under the U. S. Health Insurance Portability and Accountability Act of 1996 or HIPAA. In the case of PHI, Opaline is not a “covered entity” under HIPAA, but Opaline Customers may be. In these cases, Opaline is a HIPAA “business associate” to such Opaline Customers and, therefore, subject to some of HIPAA’s laws and regulations.

Please read this policy carefully to understand our policies and practices regarding your personal and health information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Service or the Website. By accessing or using our Service or Website, you agree to this Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy below)). Your continued use of this Website after we make changes is deemed to be acceptance of those changes.

Limitations on Use by Minors

Opaline’s Service is intended for use by individuals at least 18 years of age. We do not knowingly collect personal information from children under 13, and no one under age 13 may provide any information to or on the Website. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us by email or mail, using the Contact Information below.

Residents of certain states under 16 or 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State Privacy Rights below for more information.

Information We Collect About You and How We Collect It

Depending on the context of your interactions with our Service and Website, we may collect several types of information from you, including:

Information You Provide

  • By which you may be personally identified, such as name, postal address, email address, telephone number, age, gender, or any other identifier by which you may be contacted online or offline ("personal information")

  • In some cases, if you participate in certain elements of the Service, biometric information, such as facial scans (“sensitive personal information”)

  • That is about you, but individually does not identify you, such as browser choice and IP address; and/or

  • About your internet connection, the equipment you use to access our Service or Website, and usage details

  • Contents of communications made via the Service or Website.

Automatic Data Collection Technologies

As you navigate through and interact with our Website and the Service, we collect certain details of your visits to the Service or our Website, including technical information about your IP address, browser type, browsing actions, patterns, traffic data, location data, logs, other communication data, the resources that you access and use on the Service or the Website.

This automatically collected information may include personal information that is used to help us to improve our Service and Website.

Cookies and Other Tracking Technologies

Cookies and other tracking technologies are small files that are stored by your web browser on your computer hard drive, mobile or other devices. Like many companies, we use cookies that we set ourselves, while separate third-party entities set other cookies to analyze data traffic and other user data. For example, we use cookies from analytics providers, which can include:

  • Usage Details about your interaction with our Site, such as the pages visited, links clicked, non-sensitive text entered, mouse movements, referring URL

  • Device Information including the IP address and other details of a device that you use to connect with our Services, such as operating system, browser type, mobile network information, and the device's telephone number 

  • Profile and subscription information, such as a username and password, your name, mailing address, e-mail address, user name, or  subscription preferences, when you create an account to license the Service

  • Location information, including use of publicly available sources to approximate your geographic region and Internet Service Provider based on your IP address

Information Collected from Third Parties

If you access Opaline’s Service through a third party connection or log-in (for example, through an Opaline Customer’s website or through a social network or third-party authentication tool) you may allow us to have access to and store certain information from such third parties depending on your settings on such services. If you do not wish to have this information shared with us, you should not use these connections to access our Service. If you have questions about how any third parties handle your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings on their platforms.

How We Use Your Information

We use information we collect about you or that you provide to us or share with Opaline Customers in the following ways:

  • To present our Service and Website and their contents to you and to ensure functionality of both, such as proper display on various devices.

  • To provide you with information, products, or services that you request from us.

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection if applicable.

  • To notify you about changes to our Service or any products or services we offer or provide through it.

  • To perform any other function we believe in good faith is necessary to protect the security or proper functioning of the Service and Website.

  • To create aggregated and de-identified analytical data which we use to provide and improve our products and services, including the Service.

  • To fulfill any other purpose for which you explicitly provide it.

Use of Artificial Intelligence Tools

Our Service uses certain types of artificial intelligence, including analysis of facial images and chat tools.

Disclosing and Sharing Your Information

We may disclose de-identified and aggregated information about our users without restriction. We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To fulfill the purpose for which you provide it.

  • If you have engaged with our Service through a website or other communication from an Opaline Customer, Opaline has engaged with that Customer to provide you with the Services, and your information will be shared with them as if you had provided it directly to them. Their use of your information will be governed by the Opaline Customer’s privacy policies and practices. If you do not agree with the Opaline Customer’s privacy policies and/or practices, you should not use Opaline’s Service. Opaline will only ever share your data with an Opaline Customer where you have accessed the Service through that Opaline Customer’s unique link, such as yourmedicalspa.opaline.ai, a link that is explicitly provided to that Opaline Customer.

  • To contractors, service providers, and other third parties we use to support our business. Opaline uses various products and services from trusted third party service providers such as data analytics, maintenance and hosting of our Service, and other professional services.

  • If you interact with us on social media platforms, the platform may be able to collect information about you and your interaction with us and/or the Services. If you interact with social media objects on our Website or through the Services, that activity may be viewable by Opaline, Opaline Customers, and your connections on the social media platform.

  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Opaline Beauty Inc assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Opaline Beauty Inc. about our Website or Service users is among the assets transferred.

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

  • To enforce or apply our legal contractual rights and other agreements, including for billing and collection purposes.

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Opaline, our customers, or others.

  • For any other purpose disclosed by us when you provide the information, with your explicit consent.

Your Privacy Options

You have certain choices regarding the personal information you provide to us. You may exercise control over your information in :

  • Tracking Technologies. Some internet browsers allow you to refuse all or some browser cookies and similar technologies, or to alert you when cookies are being sent. If you disable these technologies, please note that the Service and some parts of the Website may then be inaccessible or not function properly.

  • Email and Promotional Offers. If you do not wish to have your email address used by us, or Opaline Customers you have interacted with through our Services, you can opt out by clicking on an unsubscribe link in an email you have received. You may also send us an email stating your request at privacy@joinopaline.com.

  • Global Privacy Control & Do Not Track Some browsers and browser extensions support the “Global Privacy Control” (GPC) or similar controls that can send a signal to the websites you visit indicating your choice to opt out from certain types of data processing, including data sales and/or targeted advertising, as specified by applicable privacy laws. Our Website does not detect GPC or similar signals and we will be unable to respond to your requests through this mechanism, however, we encourage you to contact us using the Contact Information below to indicate your opt-out choices. Residents of certain states may have additional personal information rights and choices.

Your State Privacy Rights

Residents of certain states, such as California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Nevada, Oregon, Tennessee, Texas, Utah, and Virginia may have additional personal information rights and choices.

As of the date of this Privacy Policy, the States listed above provide their states’ residents with rights to their personal information, which generally include some or all of the following:

  • The right to opt-out of the Company’s processing of their personal information.

  • The right to access and request deletion of certain personal information.

  • The right to request that their personal information be corrected to remove inaccuracies in their personal information, taking into account the information's nature processing purpose.

  • The right to request that their personal data be ported to an alternate provider.

  • The right to opt-out of personal data processing for targeted advertising (excluding Iowa), sales, or profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).

  • The right to either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise any of these rights or to appeal a decision regarding a rights request, please write to privacy@joinopaline.com.

Data Security

We use commercially reasonable physical, technical, administrative, and measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on secure servers behind firewalls.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website or the Services.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page at www.joinopaline.com/privacy. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, you can contact us at:

privacy@joinopaline.com

Or by mail at:

PO Box 48
New York, NY 10272