Wella Virtual Try-On Privacy Notice

Last Updated: February 21, 2024

This privacy notice (“Notice”) describes how Wella (which is operated by Wella International Operations Switzerland S.à.r.l. and its affiliates) (“Wella”, “us”, “our”) collects and uses your personal information via the web properties, including www.clairol.com (the “Site”) while using the Virtual Try-On service (“the Service”).

The Wella Privacy Notice found at: www.wellacompany.com/privacy-policy shall govern the collection and processing of any personal information in relation to the Service, including any biometric information or biometric identifiers. Please read this notice carefully as it describes in detail the rights and responsibilities regarding processing of your personal information.

In addition, the following supplementary terms shall also apply, specifically to your use of the Service:

Supplementary Privacy Notice Terms

1. What personal information do we collect and for what purpose?

With your consent, Wella and Wella’s service provider, Perfect Corp., may process the biometric information on your device in connection with your use of the Service. The biometric data will not be transmitted from your device during the Service or after the Service is finished. Perfect Corp., Wella and other Wella service providers (on behalf of Wella) may also securely process other (non-biometric) personal information in connection with the Service.

The method by which Wella processes biometric information, the biometric information that is processed, and the purpose of processing depends on the type of Service you are using:

• Hand Scan: The Virtual Try-On Services uses a camera to collect an image of your hand for the purpose of demonstrating a nail color application.
• Face Scan: The Virtual Try-On Services uses a camera to take a photograph of your face for purposes of demonstrating the application of a hair color.

Once an image is taken, the Service uses the information to apply the shade of the product you have selected and demonstrate the product application. The resulting images are illustrative only and actual product results will vary.

We may also collect contact information and related non-biometric personal information (email address, Facebook account handle and IP address) in connection with the Service. Contact information is used for the purpose of emailing or sharing the image with you, or others you indicate, should you choose to use this functionality.

2. How long does Wella retain biometric information?

The information collected from use of the Service shall be retained until the earlier of: (a) our receipt of your request to delete the information, (b) the initial purpose for collecting or obtaining the information has been satisfied, or (c) the information is automatically deleted 3 years after the user’s last interaction with the Service.

3. Who will process your personal information?

With your consent, Wella and Wella’s service provider, Perfect Corp., may process the biometric information in connection with your use of the Service in your device, the biometric data will not be transmitted during the Service or after the Service is finished. Wella and Perfect Corp. may also disclose biometric information where required by applicable law or is in response to subpoenas, court orders, or other legal processes. Biometric information may be disclosed or disseminated to Perfect Corp., or from Perfect Corp. to Wella, using the reasonable standard of care within Wella’s industry, and in at least the same manner utilized by Wella to store, transmit, or protect other confidential or sensitive information.

Perfect Corp., Wella and other Wella service providers (on behalf of Wella) will securely process your other (non-biometric) personal information.

4. For what purposes is your personal data processed?

Your biometric information, including scans of hand or face geometry, any other images/video data may be used only to apply the shade to demonstrate the product result, though note the images are indicative only and actual product results will vary. Biometric information may not be collected for any purpose other than for product demonstration purposes.

5. What are my rights and how can I withdraw my consent?

You may have the right to withdraw your consent for our processing of biometric information about you and have such information deleted from our systems. Wella provides further description of your rights and instructions on how to withdraw your consent in the Wella Privacy Notice found at https://www.wellacompany.com/en-us/privacy-policy. If Wella is unable to fulfill your request to delete biometric information about you, you may appeal the decision through our Data Protection Team by submitting your question via the customer affairs form, found via this link on the Wella website at www.clairol.com/contact-us. Please include the words “Deletion Request Appeal” in the subject heading of your request. More information regarding the appeal process will be provided in our correspondence with you regarding the denial of your request.

6. Where can I find out more information and contact Wella with any questions?

Please see the Wella Privacy Notice found at www.wellacompany.com/privacy-policy including the ‘How do I Contact Wella?’ section.