Privacy Policy

1. Background

1.1 For the purpose of the EU General Data Protection Regulation (GDPR), the data controller is My Beauty Guide and Club ApS, Rådhustorvet 7, 2nd floor, 3520 Farum, Denmark, company registration number (CVR) 45193691 ("My Beauty Guide and Club", "we" or "us").

1.2 My Beauty Guide and Club ApS has developed the My Beauty Guide app and the website mybeautyguide.dk – an online universe for beauty products, where users can rate beauty products and share experiences (together the "Service").

1.3 As a registered user you can review and rate beauty products. These can be products others have created or products you create yourself. "You" or "User" means any user of the Service.

1.4 We know that you care about how your personal information is used, and we take your privacy seriously. This Privacy Policy describes how we process personal information when you use the Service.

2. Children under the age of 13

2.1 The Service is not directed to children under the age of 13. Children under 13 may not register, and we do not knowingly collect personal information from them.

3. Information you give us

3.1 We collect and process information in several ways when you use the Service:

• When you register, we ask for basic personal information such as your name and e-mail address, which is stored with your account.
• If you register using your Facebook account, we receive information from your public profile, your profile image and your e-mail address from Facebook.
• We store the information you provide when using the Service, including your reviews and comments.
• Uploading a profile image is optional. If you do, it helps you personalise your profile and reviews.
• When you upload your own product image, it helps other users recognise the product.

4. Information we collect automatically

4.1 We receive and store certain information about your use of the app, for example the posts you read or like. Our server logs automatically store your device ID and type, language, operating system, access times, the geographic location of your device (if enabled) and referring third-party services. More generally, we collect information about how often you use the app.

4.2 On the website we only use cookies for statistics (Google Analytics and Hotjar) and marketing (Meta Pixel) if you have consented to this in our cookie banner. You can read more about each cookie, and change or withdraw your consent, in our cookie policy (in Danish).

4.3 To document your cookie choice, we store a random consent ID, your choice, the time, the page you were on and your browser type. We do not store your IP address for this purpose.

5. How we use your information

5.1 In general we use the information we collect to:

• deliver and improve the Service
• improve the relevance of the ads you see in the app
• manage your account and provide customer support
• produce statistics about the use of the app and website
• enforce our terms of use
• perform functions or services as described at the time of collection

5.2 We use your ratings and reviews of beauty products to market the products in general online or in print. If we wish to use your specific review for marketing purposes, we will ask for your consent first.

5.3 We process your personal information on the following legal bases:

• your consent, e.g. to statistics and marketing cookies (GDPR art. 6(1)(a))
• to provide the Service and your account to you (GDPR art. 6(1)(b))
• our legitimate interest in operating, securing and improving the Service and documenting consents (GDPR art. 6(1)(f))

6. Who we share information with

6.1 We do not sell your personal information. We show ads, campaign offers, invitations and events from third parties based on your favourite products, the products you have reviewed or the products you have listed as "Must Have" in the app – without sharing your personal information with the advertisers.

6.2 We never disclose aggregated information to a partner in a way that identifies you.

6.3 We use the following recipients of personal information:

• Microsoft Ireland Operations Ltd. (Microsoft Azure), which hosts and operates the Service for us (see section 9)
• if you have consented: Google Ireland Ltd. (Google Analytics), Hotjar Ltd. and Meta Platforms Ireland Ltd. (Meta Pixel). Google and Meta may transfer information to the USA on the basis of the EU-U.S. Data Privacy Framework and/or the European Commission's standard contractual clauses.

7. Third-party services

7.1 This Privacy Policy only covers the personal information we collect ourselves. If you disclose your information to others, or if you are directed to a third-party website (e.g. a web shop via a price link), their privacy policies apply. These services may independently collect information about you and in some cases provide us with information about your activities with them. We recommend that you read the privacy policies of the third-party services you use.

8. Disclosure for legal and security reasons

8.1 We may release personal information when we in good faith believe it is necessary to:

• comply with legal requirements
• enforce our terms of use and other agreements
• protect the rights, property or safety of us, our employees, our users or others

This includes exchanging information with other companies and organisations for fraud protection.

8.2 Except as set out above, you will be notified when your personal information may be shared with third parties, and you will be able to prevent it.

9. Security and storage

9.1 We do our best to protect your information. However, no solution is completely secure, and unauthorised access, hardware or software failure and other factors may compromise security.

9.2 Your personal information is stored with our data processor Microsoft (Microsoft Azure):

• The website runs in Microsoft's data centre in the Netherlands (EU).
• The database with accounts, reviews and consents is in Microsoft's data centre in the United Kingdom. The European Commission has decided that the United Kingdom provides an adequate level of protection (adequacy decision).
• Images, including profile and product images, are stored in Microsoft's data centre in the USA. The transfer is based on the EU-U.S. Data Privacy Framework and the European Commission's standard contractual clauses in Microsoft's data processing agreement.

9.3 Our data processors only process information on our instructions, and we have entered into data processing agreements with them. We are fully responsible for the processing and ensure that our data processors have taken the necessary technical and organisational security measures to prevent the information from being accidentally or unlawfully destroyed, lost, impaired or misused.

9.4 We keep your information for as long as you have an account, or as long as necessary for the purposes described above. Your cookie consent is valid for 12 months, after which we ask again. The record of your cookie choice (section 4.3) is automatically deleted after 3 years.

10. Your rights

10.1 You have the right to:

• access the personal information we hold about you
• have inaccurate information corrected
• have your information deleted or its processing restricted
• object to our processing
• receive your information in a common machine-readable format (data portability)
• withdraw your consent at any time – this does not affect the lawfulness of processing before withdrawal

The right of access may be limited by law in some circumstances. Please note that you may not be able to use the app if you request deletion of your information, object or withdraw your consent.

10.2 For any inquiries regarding your personal information, please write to hello@mybeautyguide.app.

10.3 You can complain about our processing of your personal information to the Danish Data Protection Agency (Datatilsynet), Carl Jacobsens Vej 35, 2500 Valby, Denmark, datatilsynet.dk, e-mail: dt@datatilsynet.dk.

11. Amendments

11.1 This Privacy Policy may be amended from time to time. Amendments that require your consent will only take effect once you have given it. If you do not consent to a new privacy policy, you may not be able to use the Service.

12. Questions

12.1 Please send any questions regarding privacy to hello@mybeautyguide.app.