Privacy Policy

Last updated April 22, 2024

This privacy notice for NEXAI AI, Inc. ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

  • Download and use our mobile application (Glam U), or any other application of ours that links to this privacy notice
  • Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by scrolling below.

  • What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
  • Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.
  • Do we receive any information from third parties? We do not receive any information from third parties.
  • How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
  • In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.
  • How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information.
  • What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Disclose to Us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Face Data Collection and Usage

Our app collects and processes facial data for the following specific purposes:

  • Virtual try-on of makeup and beauty products
  • Facial feature analysis for personalized beauty recommendations
  • Creation of virtual makeup looks
Face Data Storage and Security

All face data is processed locally on your device and is not permanently stored on our servers. Any temporary server-side processing is performed using encrypted connections and the data is immediately deleted after processing. We do not share your face data with any third parties.

Face Data Retention

Face data is retained for the duration of your active account and is automatically deleted when you delete the account. If you choose to save specific looks or results, only the final processed images are stored, not the original face data.

Your Control Over Face Data

You have complete control over your face data:

  • You can choose when to allow camera access for face detection
  • You can delete all face data through the email
  • You can disable face detection features at any time

Payment Data

We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Apple. You may find their privacy notice link(s) here: https://www.apple.com/legal/applepayments/privacy-notice/.

Application Data

If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

  • Mobile Device Access: We may request access or permission to certain features from your mobile device, including your mobile device's camera, photo library, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
  • Mobile Device Data: We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server).
  • Push Notifications: We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To deliver and facilitate delivery of services to the user.
  • To request feedback.
  • To identify usage trends.
  • To determine the effectiveness of our marketing and promotional campaigns.
  • To save or protect an individual's vital interest.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent.
  • Performance of a Contract.
  • Legitimate Interests.
  • Legal Obligations.
  • Vital Interests.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

We may share your data with third-party vendors, service providers, contractors, or agents (“third parties“) who perform services for us or on our behalf and require access to such information to do that work.

We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it.

They will also not share your personal information with any organization apart from us.

They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

We also may need to share your personal information in the following situations:

  • Business Transfers.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice, up to a maximum of one year, unless otherwise required by law.

We will only keep your personal information for as long as it is necessary to provide you with access to your previous scan results.

We will only keep your face scans for a maximum of one year, unless required otherwise by law.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age.

By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws.

These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.

At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized.

10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Utah or Virginia, you are granted specific rights regarding access to your personal information.

We have collected the following categories of personal information in the past twelve (12) months:

  • Biometric information
  • Sensitive personal Information

11. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

12. DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at [email protected] or contact us by post at:

NEXAI Inc.

1312 17TH ST STE 2199

Dover, CO 80202

United States

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it.

To request to review, update, or delete your personal information, please fill out and submit a data subject access request: [email protected]

15. FACE DATA HANDLING SPECIFICS

What is Face Data?

Face Data refers to the images that you provide, which are essential for conducting our makeup and bare-face analysis services.