Privacy Policy
This privacy statement (Privacy
Statement) explains how Zellor Ltd (BeautyBuzz, we, us and our)
may collect, use, store and disseminate information obtained from users (Personal
Data) of its and mobile apps and website, disco.club (the Site), and the content and
services available on the mobile apps and Site, and offered by (taken
together, the Services). This Privacy Statement also describes your
rights regarding the use of your Personal Data where the EU General Data
Protection Regulation (GDPR) applies for you.
Your privacy is very important to us
and we pay close attention to how information about our visitors is used and
shared.
1. Personal Data Collected
A. Personal Data we collect and process
i. Engagement with our Services
We obtain various types of Personal Data when providing our Services. Such
Personal Data may include contact information such as names, addresses, phone
numbers, email addresses, date of birth, gender and interests; information
about products and services ordered or provided; and information collected
related to gauge interest in Internet-based e-commerce capabilities or provide
technical literature or product demos.
ii. Device Information
When using the Site or availing of services related to the Site, Personal Data
will be collected from you by BeautyBuzz. This includes information about:
Internet protocol (IP) addresses, device IDs, browser type, Internet service
provider (ISP), referring/exit pages, operating system, date/time stamp, and/or
clickstream data to analyse trends in the aggregate and administer the site. We
do not link this automatically collected information to other Personal Data we
collect about you.
B. Personal Data you can choose to share with us
i. Query and Form Information
At your election, you may desire to subscribe or gain access to various information
services concerning BeautyBuzz products, services, user groups and business.
When you do so, our registration process may require you to provide your name,
address, telephone number, gender, email address and certain additional
information, such as, for example, your preferred contact method and product
markets of interest to you. You may also share Personal Data when contacting us
and submitting enquiries through the Site or by filling in the contact form on
the Site.
2. How and Why we use your Personal
Data
The following table details the legal basis for
(the Legal Basis) and the reasons why (Purposes) we process your Personal
Data:
Legal Bases & Purposes
Performance of a Contract
Legal Basis
It is necessary to process your Personal Data to enter
into and perform our contract with you as part of our Services.
Purposes
Enter into and Perform our Contract with you
�
To provide our services
�
To fulfil orders
�
To process payments
�
To provide customer services
IMPORTANT
You are obliged to provide us with your
Personal Data as it is necessary to enter into a contract with us, for our
Services. In the event that you do not wish to provide us with your Personal
Data for the above purposes, you will not be able to avail of our Services.
Legitimate Interests
Legal Basis
It is necessary for the purpose of our
legitimate interests to collect and process your Personal Data where we have a
legitimate interest to do so as part of your engagement with our Site and
Services.
Purposes
Improving Site Functionality & Efficiency
�
To provide, improve, test and monitor
the effectiveness of the Site and Apps
�
To monitor metrics such as total number
of visitors, traffic data and demographic patterns.
To respond to your Queries or Requests
�
To respond to your inquiries for
information and to provide additional information according to your
preferences.
�
To facilitate BeautyBuzzs�
relationship with investors.
Promotional or Marketing Materials
�
To process your Personal Data to send
you information about BeautyBuzz and its products, services and business
partners.
�
At your election, at any time, you may
choose to stop receiving future marketing communications from BeautyBuzz by
sending an e-mail to [email protected] or
clicking the [unsubscribe] link in communications you receive.
Improve BeautyBuzz Services
�
To better our services offering through
online surveys and focus groups.
�
To provide and process satisfaction
surveys, policy surveys and referral forms.
IMPORTANT
Before we process your Personal Data to
pursue our legitimate interests for the above purposes, we determine if such
processing is necessary and we carefully consider the impact of our processing
activities on your fundamental rights and freedoms. On balance, we have
determined that such processing is necessary for our legitimate interests and
that the processing which we conduct does not adversely impact on these rights
and freedoms.
If the GDPR applies for you, you have a
number of rights in relation to your Personal Data which are set out below. In
particular these rights include the right to object to processing of your
Personal Data where that processing is carried out for our legitimate
interests.
Compliance with a Legal Obligation
Legal Basis
It is necessary to process your Personal Data in
order to comply with legal obligations to which we are subject.
Purposes
We obtain, collect and process your Personal Data
in order to comply with the following legal obligations:
�
To comply with applicable company and
tax law.
�
To comply with all other applicable
laws.
In certain situations, BeautyBuzz may be
required to disclose personal data in response to lawful requests by public
authorities, including to meet national security or law enforcement
requirements. BeautyBuzz may also disclose personal information if (1)
reasonably necessary to perform the Service, (2) permitted under this Privacy
Statement or (3) BeautyBuzz is required to do so by law or regulation, or in the
good faith belief that such action is necessary to (i)
conform or comply with any legal, regulatory, law enforcement, bankruptcy proceedings,
or similar requirement or investigation, (ii) protect or defend the rights or
property of BeautyBuzz or any other user.
BeautyBuzz may disclose Personal Data to
some or all of the following recipients:
|
RECIPIENT(S) |
|
BeautyBuzz and group companies
of BeautyBuzz (�BeautyBuzz Group�) � Members and shareholders of the BeautyBuzz Group |
|
Third Party Service Providers � Joint venture partners |
Other Recipients
� Prospective buyers of business assets (to facilitate
the acquisition of BeautyBuzz or a substantial portion of BeautyBuzz assets by a
third party)
� Regulatory authorities and law enforcement agencies
(where we are under a duty to disclose or share your Personal Data in order to
comply with any legal or regulatory obligation or request)
� External advisors e.g. lawyers, accountants and
auditors (as necessary to protect BeautyBuzz� legitimate and legal interests)
If BeautyBuzz is involved in a merger,
acquisition, or sale of all or a portion of its assets, you will be notified
via email and/or a prominent notice on our Site of any change in ownership or
uses of your Personal Data, as well as any choices you may have regarding your
Personal Data. In the event we so disclose personal information to third parties,
we require these third parties to use your personal information only as
necessary to help us perform the Service. BeautyBuzz may transfer Personal Data
to any successor to all or substantially all of its business or assets that
concerns the Service. We will share your personal information with third
parties only in the ways that are described in this Privacy Statement.
4. Transfers of Your Personal Data
BeautyBuzz has global hosting centers that store and process your Personal Data in
various locations around the world including in the United States and the
European Economic Area (�EEA�).
We only transfer your Personal Data
outside the EEA where the European Commission has decided that the third
country in question ensures an adequate level of protection in line with EU
data protection standards or there are appropriate safeguards in
place to protect your Personal Data.
Where we transfer Personal Data to
other entities within the BeautyBuzz Group, we do so on the basis of Standard
Contractual Clauses which are a form of data processing contract approved by
the European Commission. You can find a copy of these clauses here.
For further information, please contact
our Privacy Officer [email protected].
5. Security
The security of your Personal Data is
important to us. We follow generally accepted standards to protect the Personal
Data submitted to us, both during transmission and once we receive it.
Information collected by BeautyBuzz is stored in secure operating environments
that are not made generally available to the public. Unfortunately, no data
transmission over the Internet can be guaranteed to be 100% secure. However, we
are committed to taking reasonable and appropriate steps to protect your
Personal Data that we hold from misuse, loss, or unauthorized access. We do
this by having in place a range of appropriate technical and organizational
measures. If you have any questions about the security of your personal
information, you can contact us at [email protected].
6. Third Party Sites
The Site may contain links to other
websites (�Third Party Sites�) on the Internet, and other websites may
contain links to the Site. Third Party Sites are not under BeautyBuzz� control.
The privacy and security practices of Third Party Sites are not covered by this
Privacy Statement, and BeautyBuzz is not responsible for the privacy or security
practices or the content of Third Party Sites. We recommend that you
familiarize yourself with the privacy policies and practices of Third Party
Sites.
7. Tracking Technologies
As is true of most websites, we gather
certain information automatically and store it in log files. This information
may include Internet protocol (IP) addresses, browser type, Internet service
provider (ISP), referring/exit pages, operating system, date/time stamp, and/or
clickstream data to analyse trends in the aggregate and administer the site. We
do not link this automatically collected data to other information we collect
about you.
BeautyBuzz and our partners for
instance, our marketing analytics service provider Google Analytics and video
hosting partners YouTube and Vimeo use cookies or similar technologies in analysing
trends, administering the site, tracking users� movements around the site and
to gather demographic information about our user base as a whole. We may
request reports based on the use of these technologies by our marketing
analytics service provider partners on an individual as well as aggregated
basis.
We use cookies for marketing analytics.
Users can control the use of cookies at the individual browser level. If you
reject cookies, you may still use our site, but your ability to use some
features or areas of our site may be limited.
8. Widgets and Social Media Features
Widgets support functions that require
that you disclose certain personal information given the user�s choice of
participation. This information is collected in many different ways such as:
forms, surveys, contests, forums, subscribing or unsubscribing to mailings and
correcting or updating personal information and are only used for the purpose
in which they were collected.
Our Site includes social media features
such as the Facebook �Like� button and Widgets such as the �Share This� button
and also interactive mini-programs (�Social
Media Features�) that run on our Site. Our Social
Media Features may collect your IP address, information about which page you
are visiting on our Site, and may set a cookie to enable the Social Media
Features to function properly.
Social Media Features and Widgets are
either hosted by Third Party Sites or hosted directly on our Site. Your
interactions with Social Media Features on Third Party Sites are governed by
the privacy policy of the relevant Third Party Site. We recommend that you
familiarize yourself with the privacy policies and practices of Third Party
Sites.
9. Behavioral
Targeting/ Re-Targeting
Our third party partners may use
technologies such as cookies to gather information about your activities on
this site and other sites in order to provide you advertising based upon your
browsing activities and interests. If you wish to not have this information
used for the purpose of serving you interest-based ads, you may opt-out by
clicking here (or if located in the European Union click here).
Please note this does not opt you out of being served ads. You will continue to
receive generic ads.
10. Data Retention
We
expect to keep your Personal Data for as long as is necessary for the purposes
for which it was obtained from the date of collection. Once we have determined
that we no longer need to hold your Personal Data, we will delete it from our
systems. For example, we may hold your data if we are processing an ongoing
claim or believe in good faith that the law or a relevant regulator may
reasonably in our view expect or require us to preserve your Personal Data.
11. Blogs and Testimonials
If you use a bulletin board or, blog on
this Site, you should be aware that any Personal Data you submit there can be
read, collected, or used by other users of these forums, and could be used to
send you unsolicited messages. We are not responsible for the personal
information you choose to submit in these forums. To request removal of your
personal information from our blog or forum, please contact us at our contact
details set out in Section 16. In some cases, we may not be able to remove your
personal information, in which case we will let you know if we are unable to do
so and why.
We also have testimonials on our site
which display personal information. The individuals who have provided these
testimonials have given permission to have their personal information and
testimonial displayed. If you wish to update or delete your testimonial, you
can contact us.
12. User Access and Choice
You may elect to not receive future
marketing communications from BeautyBuzz by sending an email to [email protected] that
includes your electronic mail address; provided, BeautyBuzz reserves the right
to use your contact information to send you important information (such as, for
example, information about products and services that you have acquired from BeautyBuzz
or information about changes to this Privacy Statement).
Upon request BeautyBuzz will provide you
with information about whether we hold any of your Personal Data. If you wish
to have access and correct, update or delete inaccurate data, please contact us
at [email protected]. We will respond within 1 month of your request.
We may extend this up to 2 months if necessary however we will inform you if
this arises.
13. Rights under the EU General Data Protection
Regulation (�GDPR�)
If the GDPR applies for you, you have a
number of rights in relation to your Personal Data which are set out in section
13. In particular these rights include the right to object to
processing of your Personal Data where that processing is carried out for our
legitimate interests. Note that in certain circumstances these rights might
not be absolute.
|
Right |
Further Information |
|
Right of Access |
You have the right to request a copy
of the Personal Data held by us about you and to access the information which
we hold about you. We will only charge you for making such an access request
where we feel your request is unjustified or excessive. |
|
Right to
Rectification |
You have the right to have any
inaccurate Personal Data which we hold about you updated or corrected. |
|
Right of Erasure |
In certain circumstances, you may
also have your personal information deleted, for example if you exercise your
right to object (see below) and we do not have an overriding reason to
process your Personal Data or if we no longer require your Personal Data for
the purposes as set out in this notice. |
|
Right to
Restriction of Processing |
You have the right to ask us to
restrict processing your Personal Data in certain cases, including if you
believe that the Personal Data we hold about you is inaccurate or our use of
your information is unlawful. If you validly exercise this right, we will
store your Personal Data and will not carry out any other processing until
the issue is resolved. |
|
Right to Data
Portability |
You may request us to provide you
with your Personal Data which you have given us in a structured, commonly
used and machine-readable format and you may request us to transmit your
Personal Data directly to another data controller where this is technically
feasible. This right only arises where: (1) we process your Personal Data
with your consent or where it is necessary to perform our contract with
you; and (2) the processing is carried out by automated
means. |
|
Right to Object |
You have a right to object at any
time to the processing of your Personal Data where we process your Personal
Data on the legal basis of pursuing our legitimate interests. Please note that you may opt-out of
receiving marketing information from BeautyBuzz by contacting us at [email protected] |
You can exercise any of these rights by
submitting a request to our Privacy Officer in writing at the following email
address: [email protected].
We will provide you with information on
any action taken upon your request in relation to any of these rights without
undue delay and at the latest within 1 month of receiving your request. We may
extend this up to 2 months if necessary however we will inform you if this
arises. Please note that we may ask you to verify your identity when you seek to
exercise any of your data protection rights.
You also have the right to lodge a
complaint about the way we handle or process your personal data with your
national data protection regulator. For further information please see here.
14. The Consumers of our Clients
BeautyBuzz provides a wide variety of
services and solutions to our business clients (�Clients�) that
facilitate services related to the online provisioning and activation of
network and home-based services. BeautyBuzz develops systems to interface with
our Clients� online order capture systems and receives information for each
order about the individual that placed the order (�Consumer�). In all
instances, BeautyBuzz will obtain access to Personal Data about Consumers (�Consumer
Personal Data�) in the course of fulfilling the order and or services
offered on our Client�s website. Consumer Personal Data may include, name,
address, phone, email address, credit or bank card number, billing history and
other information, depending on the particular Client and application at issue.
We also supplement data such as credit verification status and address
validation services.
Wherever we obtain access to Consumer
Personal Data, we are acting as a data processor on behalf of our
Clients, and we therefore conduct such activities strictly in accordance with
their instructions and pursuant to our contractual arrangements with them. If
you are a Consumer with an existing relationship with one of our Clients, you
should refer to the Client�s website to understand their privacy practices and
policies. Where the GDPR applies for you and you would like to access and
review your Consumer Personal Data, you should contact our Client with any such
requests. We will cooperate as appropriate with requests from our Clients to
assist with such requests.
15. Revisions and Updates to the Privacy Statement
If
we decide to change our Privacy Statement, we will post those changes to this
Privacy Statement, the home page, and other places we deem appropriate so that
you are aware of what Personal Data we collect, how we use it, and under what
circumstances, if any, we disclose it. Personal Data collected by the Site is
subject to the Privacy Statement in effect at the time of use. We reserve the
right to modify this Privacy Statement at any time, so please review it
frequently. If we make material changes to this policy, we will notify you
here, or by means of a notice on our home page prior to the change becoming
effective.
If you have an unresolved privacy or
data use concern that we have not addressed satisfactorily, please contact our
third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
16. California Consumer Privacy Act
BeautyBuzz has published a CCPA privacy
statement, which can be found on the company website or at the link below:
https://www.disco.club/CCPA-Privacy-Statement.pdf
17. Questions about this Privacy Statement
If you have any questions regarding
this Privacy Statement or your dealings at this Site, or a request to correct or
delete personal information, please contact please contact the BeautyBuzz
Privacy Officer:
Zellor Ltd.
Attn: Privacy Officer
17 Longford Terrace
Monkstown, Dublin
Ireland
Email: [email protected]
We will use commercially reasonable
efforts to fulfil your request in a timely manner.
Last Updated January 13, 2022