Clockwork Privacy Policy – Clockwork
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Clockwork Privacy Policy

Last updated: March 4, 2024

Elementree Inc., d/b/a Clockwork (“Clockwork”) provides access to the services of the “Robot”, an autonomous machine (including all related software, algorithms, logic and structure) that applies nail polish, including for use in manicures, and the website located at https://www.likeclockwork.local/ (“Site”). Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and share your personal information and to assist you in exercising the privacy rights available to you. By enrolling on the Site or signing up for services of the Robot, or otherwise communicating with Clockwork, you accept and agree to our Privacy Policy.

SCOPE

This Privacy Policy applies to personal information processed by us in our business, including on our websites, the Robot, and other online or offline offerings (collectively, the “Services”).

I. PERSONAL INFORMATION WE COLLECT

Information You Provide to Us.

Account Creation: When you create a user account, we collect your name, email address, phone number, username, and password.

Your Communications with Us. We collect personal information from you such as email address, or phone number when you request information about our Services, request customer or technical support or otherwise communicate with us, including by booking an appointment.

Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

Social Media Content. We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.

Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.

Information Collected Automatically or From Others

Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services.  Information we collect may be associated with accounts and other devices.

In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities.

Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

  • Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

Images. We will collect 3D and 2D images and videos of your fingers in connection with your use of the Services, and use this image to identify the surface of your nails; we will not use this image to identify you, and we will use this image solely in connection with the provision and improvement of the Services. We do not collect your fingerprint data.

Information from Other Sources. We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email, profile picture, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.

II. HOW WE USE YOUR INFORMATION. 

We use your information for a variety of business purposes, including to:

Fulfill our contract with you and provide you with our Services, such as:

  • Managing your information and accounts;
  • Providing access to certain areas, functionalities, and features of our Services;
  • Communicating with you about your account, activities on our Services and policy changes;
  • Undertaking activities to verify or maintain the quality or safety of a service or device;
  • Processing your financial information and other payment methods for products or Services purchased;
  • Providing advertising, analytics and marketing services;
  • Providing Services on behalf of our customers, such as maintaining or servicing accounts, providing customer service, and verifying customer information; 
  • Processing applications and transactions; and
  • Allowing you to register for events.
  • Sending promotional and transactional mobile messages in various formats 


Analyze and improve our Services pursuant to our legitimate interest, such as:

  • Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads;
  • Undertaking research for technological development and demonstration;
  • Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
  • Improving, upgrading or enhancing our Services or device;
  • Developing new products and Services;
  • Ensuring internal quality control;
  • Verifying your identity and preventing fraud;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Enforcing our terms and policies; and
  • Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.

Provide you with additional content and Services, such as:

  • Furnishing you with customized materials about offers, products, and Services that may be of interest, including new content or Services; and
  • Other purposes you consent to, are notified of, or are disclosed when you provide personal information.

Use De-identified and Aggregated Information. We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.

Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.

How We Use Automatic Collection Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Our uses of these Technologies fall into the following general categories: 

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
  • Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
  • Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
  • Advertising or Targeting Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third party sites.

Notice Regarding Third Party Websites, Social Media Platforms and Software Development Kits. The Services may contain links to other websites, and other websites may reference or link to our website or other Services.  These other websites are not controlled by us.  We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Our Services may include publicly accessible blogs, forums, social media pages, and private messaging features. By using such Services, you assume the risk that the personal information provided by you may be viewed and used by third parties for any number of purposes. In addition, social media buttons such as Facebook and Twitter (that might include widgets such as the “share this” button or other interactive mini-programs) may be on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features apart from your visit to our site are governed by the privacy policy of the company providing it.

Mobile Messaging Terms And Conditions. We may send promotional and transactional mobile messages in various formats to you. Promotional messages advertise and promote our products and services and may include promotions, specials, other marketing offers, and abandoned checkout reminders. Transactional messages relate to an existing or ongoing transaction and may include appointment reminders, and other transaction-related information. Mobile messages may be sent using an automated technology, including an autodialer, automated system, or automatic telephone dialing system. Message frequency will vary. You agree that we, our affiliates, and any third-party service providers may send you messages regarding the foregoing topics or any topic and that such messages and/or calls may be made or placed using different telephone numbers or short codes, except in connection with marketing purposes. We do not charge for sending mobile messages but you are responsible for any message and data rates imposed by your mobile provider, as standard data and message rates may apply for short message service and multimedia message alerts.

User Opt-In: By providing your mobile phone number to us, you are voluntarily opting in and you agree to receive recurring mobile messages from us at the mobile phone number associated with your opt-in, even if such number is registered on any state or federal “Do Not Call” list. You agree that any mobile phone number you provide to us is a valid mobile phone number of which you are the owner or authorized user. If you change your mobile phone number or are no longer the owner or authorized user of the mobile phone number, you agree to promptly notify us at +1 (201) 992-4470. Your participation to receive mobile messages does not require that you make any purchase from us and your participation is completely voluntary.

User Opt-Out and Support: You may opt-out of receiving mobile messages at any time. If you wish to opt-out and stop receiving mobile messages from us, or you no longer agree to these Mobile Messaging Terms, reply STOP, QUIT, CANCEL, OPT-OUT, and/or UNSUBSCRIBE to the mobile number the message is sent from. You may continue to receive text messages for a short period while we process your request and you may receive a one-time opt-out confirmation message. You understand and agree that the foregoing is the only reasonable method of opting out. If you want to receive mobile messages again, just sign up as you did the first time, and we will start sending messages to you again. For support, reply HELP to any mobile message from us.

Our mobile messaging platform may not recognize requests that modify the foregoing commands, and you agree that we and our service providers will not be liable for failing to honor requests that do not comply with the requirements in these Mobile Messaging Terms. We may also change the telephone number or short code we use to send mobile messages and we will notify you of any such change. You acknowledge that any requests sent to a telephone number or short code that has been changed may not be received by us and we will not be responsible for failing to honor a request sent to a telephone number or short code that has been changed. You agree that neither we nor our service providers will be liable for any failed, delayed, or misdirected delivery of any mobile message or information.

We may modify or cancel mobile messaging or any of its features at any time, with or without notice. To the extent permitted by applicable law, we may also modify these Mobile Messaging Terms at any time. Any such modification will take effect when it is posted to our website. You agree to review these Mobile Messaging Terms periodically to ensure that you are aware of any modifications. Your continued participation in receiving mobile messages will constitute your acceptance of those modifications.

III. DISCLOSING YOUR INFORMATION TO THIRD PARTIES.

Except as provided below, we do not share/disclose/sell your personal information.

We have not disclosed consumers’ personal information in the preceding 12 months.

We have not sold consumers’ personal information in the preceding 12 months.

Service Providers. We may share any personal information we collect about you with our third-party service providers. The categories of service providers (processors) to whom we entrust personal information include: IT and related services; information and services; payment processors; customer service providers; and vendors to support the provision of the Services.

Business Partners. We may provide personal information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.

Affiliates. We may share personal information with our affiliated companies.

Advertising Partners. Through our Services, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.

Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.

IV. YOUR CHOICES. 

General.

You have certain choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal purposes as described above.

Email and Telephone Communications.

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy).

“Do Not Track.”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising.

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, and https://youradchoices.ca/choices/.

Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

Your Privacy Rights.

In accordance with applicable law, you may have the right to:

Access to/Portability of Personal Data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Personal Data transferred to another party.

Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information or we may refer you to the controller of your personal information who is able to make the correction.

Request Deletion of your personal information, subject to certain exceptions prescribed by law.

Request restriction of or object to processing of your personal information, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law.

If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

V. DATA RETENTION. 

We store the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. 

VI. SECURITY OF YOUR INFORMATION.

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

VII. CHILDREN’S INFORMATION.

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

VIII. OTHER PROVISIONS.

CHANGES TO OUR PRIVACY POLICY.

We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

IX. CONTACT US. 

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please contact us at:

Elementree Inc. DBA Clockwork

Aaron Feldstein, CTO & Data Protection Officer

founders@likeclockwork.com