Effective as of March 24, 2024

SW-Sanghvi Beauty USA, Inc. (DBA WYN BEAUTY) and our subsidiaries and affiliates ("SW-Sanghvi Beauty," "we", “us” or "our") provides, under our WYN BEAUTY brand, beauty and personal care products via a direct-to-consumer ecommerce platform. This Privacy Policy describes how SW-Sanghvi Beauty processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website and social media pages) as well as our marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”)). SW-Sanghvi Beauty may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

Index

• Personal information we collect
• Tracking technologies
• How we use your personal information
• How we share your personal information
• Your choices
• Other sites and services
• Security
• International data transfers
• Children
• Changes to this Privacy Policy
• How to contact us

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

• • Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
• • Demographic data, such as your city, state, country of residence, postal code, and age.
• • Profile data, such as the username and password that you may set to establish an online account on the Service, date of birth, redemption code, biographical details, photograph or picture, links to your profiles on social networks, interests, preferences, information about your participation in our contests, promotions, or surveys, and any other information that you add to your account profile.
• • Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
• • Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
• • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• • User-generated content data, such as photos, images, music, videos, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
• • Payment data needed to complete transactions, including payment card information or bank account number.
• • Promotion data, including information you share when you enter a competition, promotion or complete a survey. Please note that if you participate in a sweepstakes, contest or giveaway through the Service, we may ask you for your Contact Data to notify you if you win or not, to verify your identity, determine your eligibility, and/or to send you prizes. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each sweepstakes and contest that you enter.
• • Other data not specifically listed here, including data inferred or derived from the categories listed in this section, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

• • Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• • Data providers, such as information services and data licensors
• Partners, such marketing partners and event co-sponsors.
• • Customers
• • Service providers that provide services on our behalf or help us operate the Service or our business.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Location data when you authorize the Service to access your device’s location.
• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

For more information concerning our automatic collection of data, please see the Tracking technologies section below.

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.


• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.


• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.


• Session-replay technologies, such as those provided by HotJar that employ software code to record users’ interactions with the Services in a manner that allows us to watch video replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about HotJar at https://www.hotjar.com/legal/policies/privacy/, and you can find information on how to opt-out of tracking by HotJar at https://help.hotjar.com/hc/en-us/articles/360002735873-How-to-Stop-Hotjar-From-Collecting-your-Data.

For information concerning your choices with respect to the use of tracking technologies, see the Your choices section, below.

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

• • provide the Service;
• • enable security features of the Service;
• • establish and maintain your user profile on the Service;
• • communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
• • communicate with you about events or contests in which you participate; and
• • provide support for the Service, and respond to your requests, questions and feedback.

• understand your needs and interests;
• personalize your experience with the Service and our Service-related communications; and
• remember your selections and preferences as you navigate webpages.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

• • Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of communications section below.


• • Interest-based advertising. We and our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the Tracking technologies section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section below.

Events, promotions and contests. We may use your personal information to:

• • administer promotions and contests
• • communicate with you about promotions or contests in which you participate
• • contact or market to you after collecting your personal information at an event

Compliance and protection. We may use your personal information to:

• • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• • audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• • enforce the terms and conditions that govern the Service; and
• • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information below.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

• • Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
• • Functionality. To enhance the performance and functionality of our services.
• • Advertising. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.
• • Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Shopify Payments. Shopify Payments may use your payment data in accordance with its privacy policy, https://www.shopify.com/legal/privacy/app-users.
Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
Partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in SW-Sanghvi Beauty, financing of SW-Sanghvi Beauty, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of SW-Sanghvi Beauty as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your choices

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into your account.
Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
If you receive text messages from us, you may opt out of receiving further text messages from us by replying STOP to our message.  
Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.
Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
Privacy settings. We make available certain privacy settings on the Service. For example, settings related to cookies [and certain other tracking technologies] can be adjusted using the cookie banner/dashboard on our website.
Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:

• • Browser settings. Changing your internet web browser settings to block third-party cookies.
• • Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
• • Platform settings. Certain platforms offer opt-out features that let you opt-out of use of your information for interest-based advertising. For example, you may be able to exercise that option for Google and Facebook, respectively, at the following websites:

• • Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:

o AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.

• • Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.
We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to other locations where privacy laws may not be as protective as those in your state, province, or country.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

• Email: help@wynbeauty.com
• Mail: 1209 Orange Street, Wilmington, Delaware 19801