Privacy Policy

This Privacy Policy (“Policy”) describes how helloAva, Inc. (“Company” or “helloAva” or “we” or “our” or “us”) treats information collected or provided in connection with an end user’s (“you” or “your” or “User”) use of helloAva’s service, whether accessible through helloAva’s website at https://www.helloava.co, its mobile device application, instant messenger services, Short Message Service, or other electronic dialog systems (collectively, the “Services”). Please note that your use of the Services constitutes your acceptance of this Policy as set forth below.

  • Collected Information. The information collected during your use of the Services includes the following:
    • Submitted Information. As part of using the Services, you may submit certain information to us. For example, when you register for an account on the Services we will collect information from you, including Personal Information such as your first and last name, e-mail address and search terms. To the extent you provide your permission through our mobile application, we may also collect certain information from other apps on your mobile device, such as fitness tracking and weather applications. Personal Information means information such as a name, e-mail address or phone number that we can directly associate with a specific person or entity without additional information. To the extent you decline to share certain information with us, we may not be able to provide some or all of the features and functionalities found on the Services.
    • Payment Information. When you purchase products through the Services, you may be asked for your credit card, billing address, or other payment information. We use third party payment services providers to process payments on our behalf, and as a result we do not actually receive your credit card number or other payment instrument information.
    • Automatically Collected Information. When you use the Services, we gather certain non-personally identifiable information from you, and this information can be associated with your user account. This includes usage information, such as information on when, how often and for how long you use the Services, as well as server log data such as a computer’s IP address, browser type or the webpage you were visiting before you came to the Services.
    • Social Networking Information. You may share information from the Services through a social networking site such as Facebook (“Social Services”). Integration with “Social Services” allows us to offer a more personalized experience to you when you use the Website. If you share information on “Social Services”, the Social Service may provide us with access to certain information that you have provided to that Social Service (such as your profile picture, interests, and connections), and we will use, store and disclose such information in accordance with this Policy. Please remember that the manner in which “Social Services” use, store and disclose your information is governed by the terms and conditions and privacy policies of each Social Service, and not the Company.
    • Tracking and Cookies. The Services may use both web beacons and cookies to collect information. “Beacons” (also often referred to as “pixels”) are tiny graphics on a web page designed to track when a page is viewed. “Cookies” are small text files containing a string of alphanumeric characters that are downloaded by your web browser or mobile device when you visit a website. We may use both session cookies and persistent cookies when you access and use the Services. Cookies may be used, for example, to remember your user account information and your preferences, to customize the interface of the Services for you and to assist us in measuring and analyzing Service traffic. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services. Persistent cookies can be removed. Please review your browser’s documentation to learn the best way to modify your cookie settings. Like many websites, the Services does not currently respond to “do not track” browser headers. However, you can take steps to limit tracking by erasing cookies from your computer’s hard drive and by setting your browser to block all cookies or warn you before a cookie is stored.
    • Analytics. We use certain third party services to assist us in analysis, auditing, research, and reporting regarding the Services. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, we use Google Analytics to help collect and analyze certain information for the purposes discussed in this Policy. For more information about Google’s privacy practices relating to Google Analytics, please visit www.google.com/policies/privacy/partners/.
    • Retailers. Our Services may include links to third party retailers’ websites. When making purchases or using other services provided on such websites, you may submit certain information to the applicable third party retailers, including Personal Information such as your first and last name, e-mail address, date of birth, telephone number and credit card information. We receive information collected by such third party retailers, including certain demographical information (such as name and date of birth), and purchase history as well as product feedback. Please note this Policy does not apply to information that you may submit to third party retailers, other than any portion of such submitted information that we receive from the third party retailers, to which this Policy will apply. We encourage you to request from such retailers the applicable privacy policies and other terms and conditions before making a purchase or using their services.
    • Location. We will obtain your zip code number, and with your permission, your precise physical location when you are using the Services, in order to provide the features and functionality of the Services.
  • Use of Information. We internally use the information we collect as follows:
    • Provision of Services. We may use collected information for the purposes for which you provided the information including, for example, to generate cosmetic products recommendations for you, to create and maintain an account for you or to respond to a question that you e-mail to us. We also use the collected information as necessary to provide the features and functionality of the Services to you and as reasonably necessary for our business operations.
    • Updates and Troubleshooting. We may also use the collected information to contact you regarding updates or modifications to the Services or to help troubleshoot problems, provide you with required notices in connection with disputes between you and another user or alert you to changes in our policies or agreements that may affect your use of the Services.
    • Personalized Content. We may use the collected information to personalize the content that you and others see based on personal characteristics or preferences.
    • Analytics and Improvements. We may also analyze collected information relating to your use of the Services in order to help us improve the Services and develop and improve other products and services.
    • Promotional Offers. We may use the collected information to provide you with promotional materials and offers. However, we will give you the ability to opt out of receiving such e-mails in accordance with applicable law. We will not provide your personally identifiable information to third parties for their own marketing purposes without your consent.
    • Combination. We may combine personal information collected through the Services with other information that we or third parties collect about you in other contexts—such as our communications with you via e-mail, phone, or your customer service records.
  • Disclosure of Information. We share and disclose the information we collect about you as follows:
    • Transactions. If you make a purchase through the Services, the seller(s) of the product(s) shall receive your order information, including your name, contact and shipping information. Sellers are not subject to this Privacy Policy and may have their own policies and practices with regard to use and disclosure of your data. We encourage you to inquire regarding such policies and practices prior to placing an order with a seller.
    • Third-Party Service Providers. We use contractors and third-party service providers to assist us in making the Services available. Such third-party contractors or service providers may obtain access to the information you provide, including Personal Information.
    • Advertising. We may provide advertisers and other third parties with aggregated, non-personally identifiable information about our user base and its interests and usage patterns. We may also partner with third party advertising companies in order to serve online advertising regarding our products and services to users after they visit the Services. This is a common practice called “retargeting.” For more information on such practices and the ability to opt-out, you may visit www.aboutads.info.
    • Aggregated Data. We may report aggregated, anonymous data relating to activity on the Services to third parties or the general public. By way of example only, this may include the provision or publication of reports regarding the geographical distribution of our user base.
    • Business Arrangements. We may disclose non-personally identifiable information to third-party partners in furtherance of our business arrangements with them, including without limitation to jointly offer a product or service to you or create interoperability between our products and services and the products and services of such partners.
    • Transfer as Corporate Assests. In the event of a merger, sale of capital stock or assets, reorganization, consolidation or similar transaction involving Company, the information we possess, including personally identifiable information, shall be transferred as a corporate asset to the acquiring entity.
    • Legal Requirement. We will use and disclose information where we, in good faith, believe that the law or legal process (such as a court order, search warrant or subpoena) requires us to do so or in other circumstances where we believe it is necessary to protect the rights or property of Company, our users and/or third parties.
    • Affiliates. We may disclose this information to our affiliates for use as described in this Policy.
    • Sharing. Our Services may include features that by their nature support sharing certain information with other users of your choice. Those users can see your user name, information you add to your profile, and any comments or files you choose to share. Any information that you submit to such a public area of our Services, including for example a social media page or user comments page, will not be treated as confidential and will be publicly disclosed.
  • Effective Date; Changes. When we make any changes to our practices under this Policy, we will change the Effective Date. We will treat your continued use of the Services following such change as your acceptance of the changes.
  • Third Parties. The Services may contain offers from third parties or links to third-party websites. This Policy does not apply to information that you may provide to or that may be collected by third parties (other than the portion of information that we receive from third party retailers as specified in Section 1(g) of this Policy). We encourage you to request such third parties to provide you with their applicable privacy policies and other terms and conditions before engaging with or making a purchase from such third parties.
  • Viewing, Amending, and Deleting Information. You can log into your account and view or amend your account information at any time. Please note that while changes to your profile information are reflected promptly in active user databases, our servers may retain previously provided information. You can also delete your account, which ends all email notifications. We may however retain, preserve, or share your Personal Information if we believe in good-faith that we are required to do in response to a legal request or it is necessary so to defend or enforce our rights, to enforce the helloAva Terms of Use or any other agreements that we have with you, or to prevent physical injury or other harm to any person or entity, including yourself or the general public. Personal Information thereafter is destroyed, erased or de-identified. Once de-identified, we undertake not to re-identify your Personal Information. If you would like to opt out of our collection of information stored on your weather or calendar applications during your use of the Services, please adjust your privacy settings in helloAva’s Service accordingly.
  • Security. The personally identifiable information we collect about you is stored in limited access servers. We will maintain reasonable safeguards to protect the security of these servers and your personally identifiable information. However, no security measures are 100% effective and we cannot guarantee the security of your personally identifiable information. We expressly disclaim any representation or warranty, whether express or implied, with respect to ensuring, guaranteeing or otherwise offering any definitive promise of security in connection with your personal information or usage information.
  • Children Under 13. We do not knowingly collect information from children under 13 and the Services are not directed at children under 18. If you are a parent and believe your child under the age of 13 has used the Services and provided personally identifiable information to us through the Services, please contact us at the phone number and address provided in Section 11 of this Policy and we will work to delete that Service account and any such personally identifiable information.
  • Transfer to the U.S. or Other Countries. We use facilities in the United States. Your information will be stored and processed in the United States or other countries where Company has facilities. By using the Services, you consent to the transfer of information outside of your country, even if your country has more rigorous data protection standards.
  • Your California Privacy Rights. Under California law, organizations are required to provide residents of the State of California access to a privacy policy that gives consumers a choice regarding the disclosure of their personally-identifiable information to third parties for their own direct marketing purposes. If you are a California resident interested in exercising your third party disclosure choices please contact us via postal mail at helloAva, Inc., 26 Broadway, 8th Fl, Primary, New York, NY 10004, or via email at hi@helloava.co.


helloAva, Inc.
Attn. Privacy Questions
26 Broadway, 8th Fl, Primary
New York, NY 10004

Effective Date: January 17, 2017