MeNow Ltd Privacy Policy
MeNow ("The Company") operates a SaaS platform, offers related services such as consulting and project completion and acts as a data collector and processor for brands and retailers ("The Customer"). As used in this policy, "MeNow", "us", "we" and "our" refers to MeNow Ltd and its subsidiaries and affiliates. The Service refers to the website, SaaS platforms and web applications run by MeNow as well as interactions with the customers online or offline.
We are committed to protecting the information that our customers, employees and candidates share with us. This also apply to information coming from the end users of our customers, as well as our website visitors, followers, vendors, service providers, partners and others (these and any others with respect to whom we collect personal data, shall collectively be referred to as “Customers” or “you”, "your" or "end user").
Browsing through our website (www.menow.ai or www.menow.skin, "The Website") is subject to our cookies policy. In case you are providing additional information, such as contacting us for additional information, subscribing to our newsletter or registering for an account, then this policy describes how we collect and use your personal information. This statement also applies to individuals on which MeNow processes publicly available data or individuals that visit our social media pages, that provide us with information during conferences, meetings or events, in jobs or internship applications and in the course of employment or provision of services.
Reminder, by using our Service, you agree to the terms of this policy and you expressly consent to the collection, use, and disclosure of your personal information in accordance with this policy.
Information collection
We collect different types of data to provide and improve the Service.
Personal Data
While using our Service, you might be asked to give personal identifiable information that can be used to contact or identify you ("Personal Data"). Personal Data include, but not limited to, the first name and last name, email address, physical address, location, company name, job title and other types of data.
We need to collect your Personal Data so that we can provide the Services, respond to your requests for information and demonstrations, add you to our emailing lists, newsletters, marketing or promotional materials, process your purchases and other transactions with us, and process your requests for access to our Services, respond to inquiries and provide you with customer support. You might opt out of receiving promotional materials from MeNow by contacting us.
Publicly Available Data
MeNow uses publicly available data to provide and improve the Service. Our services do not include the disclosure of personal data of individuals. MeNow technology analyses the information for identifying trends and general public interests, detect benefits and adverse effects from products use, and provide corresponding analyses and reports regarding marketing, product development and potential target populations.
To perform such analyses, MeNow relies on publicly available data from several open access web sources, databases and platforms (“Publicly Available Data”). While many of such data do not fall under the definition of personal data, there might be cases in which the data file processed by MeNow include incidental data that could be considered personal data. With respect to such data, that may include platform or user generated username, pictures, as well as certain identifying or non-identifying biographical information included as free text in the data files cached, MeNow uses pseudo-anonymization techniques in an attempt to ensure that such data is processed in a de-identified manner. MeNow follows standard industry practices to ensure that the pseudo-anonymization process of such Publicly Available Data complies with the provisions.
Influencer Information and Business Information
In some cases, when MeNow analyzes publicly available data on an aggregate and statistical basis, it may find that certain individuals are effectively conducting business or engaging in commercial activities. In such instances, MeNow may use this personal data to indicate, through its system and services, to its customers that these individuals are operating in a business capacity within a particular context. This data is referred to as "Influencer Data."
Furthermore, MeNow may also collect and process publicly available data that includes business information such as business affiliations and business contacts, which are published on platforms designated for public communication of such information. This data is used to provide MeNow's customers with valuable insights relevant to their business interests, and is referred to as "Business Data."
Data that we process on behalf of our Customers
During the course of The Service, we might collect Personal Data about the end users of our Customers. As part of the services that we offer to our Customers, we store and process this Personal Data. This can include end user’s genetic material, skin microbiome data, gender, age, lifestyle information, medical and pharmaceutical history and any other Personal Data that our Customers choose to collect as part of the Service. This will almost certainly include sensitive categories of personal data such as data revealing health data, and may include other sensitive data such as data revealing racial or ethnic origin. We use this data in order to provide data driven R&D support as well as personalized recommendations to the end users.
Legal basis for processing
MeNow may process personal data when necessary to support a strictly legitimate interest. Legitimate interests typically refer to situations in which MeNow has a critical interest that cannot be achieved without using personal data, such as conducting aggregate analyses for business and commercial purposes, performing statistical analyses, initiating legal proceedings, or for security reasons. In these contexts, MeNow may also use publicly available data, such as business data from designated platforms or statistical purposes that support and inform its trend and volume analysis services and products.
When processing publicly available data, MeNow considers it to be in their legitimate interest to use such data for statistical purposes. This is in line with Article 29 Working Party Opinion 06/2014, which considers the processing of statistical data to be a legitimate interest of the controller, including in a commercial context. MeNow believes that their use of publicly available data, such as Influencer Data and Business Data, is not overridden by the rights of the data subjects. This is because the processing of such data is trivial, publicly available, and published by the individual in a business context. Moreover, this data does not involve automated decision-making or profiling, and does not pose a significant risk to the rights and freedoms of the data subjects.
It's important to note that such publicly available data is made publicly available by the data subjects themselves and can be reviewed by any internet user. Therefore, subject to appropriate safeguards, MeNow relies on its legitimate interest in using publicly available data, to the extent that the underlying datasets include any personal data.
Additionally, MeNow may use personal information to improve their website or for statistical analysis. In such instances, the basis for collecting data is MeNow's legitimate interest in conducting such improvements and analysis.
Information Sharing and Disclosure
We do not sell, trade or rent personal information to others. We may share personal information with third-party service providers to assist us in serving our customers, such as hosting providers and email service providers. These third parties also include analytics and search engine providers that assist us in the improvement and optimisation of our website, and our marketing. We endeavor to ensure that these third parties use your information only to the extent necessary to perform their functions, and to have a contract in place with them to govern their processing on our behalf.
In addition, we may also disclose personal information if required by law or in response to a subpoena or court order.
Data Security
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal information.
Data retention
MeNow will keep Personal Data it processes for only as long as necessary to provide our services and to comply with our legal obligations. We may also retain Personal Data for auditing, compliance, and business best-practices purposes.
We will delete the data upon request, unless we are legally required to retain it. Data that is no longer required may be anonymized or deleted. However, certain metadata and statistical information relating to the use of our services will not be subject to deletion procedures, and we may retain them. Please note that this information will not allow us to identify you. Some data may also be retained on third-party servers until it is deleted in accordance with their privacy and retention policies.
Cookies and Other Tracking Technologies
We use cookies and other tracking technologies to improve our website's functionality and your experience. Cookies are small text files that are stored on your device when you visit a website. We may also use web beacons and other tracking technologies to help us track user behavior and to provide you with tailored content and advertisements. You can choose to disable cookies through your browser settings.
Third Party Sites
On the MeNow website and social media accounts, there may be links to websites operated by other companies. It's important to note that MeNow does not share your personal information with those websites and is not accountable for their privacy practices. It's recommended that you review the privacy policies of those companies before interacting with their websites. Some of these third-party sites may have authorization to include the MeNow logo, even if they are not managed or maintained by MeNow. While we take great care in selecting our business partners, MeNow cannot be held responsible for the privacy practices of third-party websites that are linked to our site. Once you have left the MeNow website, we advise you to review the relevant privacy policy of the third-party website to understand how they will manage any data they collect from you.
Changes to this Policy
We may update this policy from time to time, and we will post any changes on this page. We encourage you to review this policy periodically to stay informed about how we are protecting your personal information.
Contact Information
If you have questions or concerns about our privacy policy, please contact us at info@menow.skin.
This privacy policy was last updated on February 21, 2023.
