YouCam B2C Privacy Policy
Effective Date: January 2024. This YouCam B2C Privacy Policy replaces and supersedes all prior versions.

1 This Notice

1.1 This Notice is issued by each of the Controller entities listed in Section 15 (together, "Perfect Corp.", "we", "us" and "our") and is addressed to individuals outside our organization with whom we interact, including customers, visitors to our Sites, users of our Services, other users of our Services, personnel of corporate customers and vendors, applicants for employment, and visitors to our premises (together, "you"). Defined terms used in this Notice are explained in Section 20.
1.2 This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.
1.3 You may also have certain rights regarding the information we collect about you. Specifically, the rights of Data Subjects of the EEA, Illinois and California are explained in Section 18.
1.4 Intended Audience of the Sites and Services: Our Sites and Services are not directed to children under the age of 13. As a result, our Sites and Services do not request or knowingly collect personal information from individuals under the age of 13. If you are not 13 or older, you should not visit or use our Sites and Services. We will terminate any use and accounts used by children under the age of 13 if we become aware that we have received personal information from children under the age of 13 as determined in our sole discretion, including all content and information. You may also contact us with inquiries concerning any use of children's information.

2 Collection of Personal Data

2.1 We collect or obtain Personal Data about you from the following sources:

3 Creation of Personal Data

3.1 We also create Personal Data about you in certain circumstances, such as records of your interactions with us, details of your past interactions with us, and models/templates generated based on the Personal Data you provided with us. We may also combine Personal Data from any of our Sites or Services, including where those data are collected from different devices.

4 Categories of Personal Data we Process

4.1 We Process the following categories of Personal Data about you:

5 Sensitive Personal Data

5.1 We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

5.2 If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.

6 Purposes of Processing and legal bases for Processing

6.1 The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

Processing activity Legal basis for Processing
Provision of Sites, Apps, and Services: providing our Sites, Apps, or Services; providing promotional items upon request; and communicating with you in relation to those Sites, Apps, or Services.
  • The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
  • We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, Apps, or Services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Operating our business: operating and managing our Sites, our Apps, and our services; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites, our Apps, or our services; and notifying you of changes to any of our Sites, our Apps, or our services.
  • The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
  • We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, our Apps, or our services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Communications and marketing: communicating with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; personalising our Sites and Services for you; maintaining and updating your contact information where appropriate; obtaining your prior, opt-in consent where required; enabling and recording your choice to opt-out or unsubscribe, where applicable.
  • The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
  • We have a legitimate interest in carrying out the Processing for the purpose of contacting you, subject always to compliance with applicable law (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Health and safety: health and safety assessments and record keeping; providing a safe and secure environment at our premises; and compliance with related legal obligations.
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of ensuring a safe environment at our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • The Processing is necessary to protect the vital interests of any individual.
Financial management: sales; finance; corporate audit; and vendor management.
  • We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Surveys: engaging with you for the purposes of obtaining your views on our Sites, our Apps, or our services
  • We have a legitimate interest in carrying out the Processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Security: physical security of our premises (including records of visits to our premises); CCTV recordings; and electronic security (including login records and access details).
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Legal compliance: compliance with our legal and regulatory obligations under applicable law.
  • The Processing is necessary for compliance with a legal obligation.
Improving our Sites, Apps, and Services: identifying issues with our Sites, our Apps, or our services; planning improvements to our Sites, our Apps, or our services; and creating new Sites, Apps, or Services.
  • We have a legitimate interest in carrying out the Processing for the purpose of improving our Sites, our Apps, or our services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Fraud prevention: Detecting, preventing and investigating fraud.
  • The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or
  • We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Establishment, exercise and defence of legal claims: management of legal claims; establishment of facts and claims, including collection, review and production of documents, facts, evidence and witness statements; exercise and defence of legal rights and claims, including formal legal proceedings.
  • The Processing is necessary for compliance with a legal obligation;
  • We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • The Processing is necessary for the establishment, exercise or defence of legal claims.
Recruitment and job applications: recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.
  • The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or
  • We have a legitimate interest in carrying out the Processing for the purpose of recruitment activities and handling job applications (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

7 Disclosure of Personal Data to third parties

7.1 We disclose Personal Data to other entities within the Perfect Corp. group, for legitimate business purposes and the operation of our Sites, Apps, or Services to you, in accordance with applicable law. In addition, we disclose Personal Data to:

7.2 If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data (for the content of Personal Data we collect, please see Section 2); together with any additional requirements under applicable law. We request such third-party Processor to purge the Personal Data upon the termination of relationship and upon your request for deletion.

8 International transfer of Personal Data

8.1 Because of the international nature of our business, we transfer Personal Data within the Perfect Corp. group, and to third parties as noted in Section 7, in connection with the purposes set out in this Notice. For this reason, we transfer Personal Data to Japan, US, Germany and Taiwan that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

8.2 Please note that when you transfer any Personal Data directly to any Perfect Corp. entity established outside the jurisdiction in which you are located, we are not responsible for that transfer of Personal Data. We will nevertheless Process such Personal Data, from the point at which we receive those data, in accordance with the provisions of this Notice.

Recipient's Contact Info Country Date, Time and the transfer method Transferred personal data Purpose Retention period
Perfect Corp.
privacyteam@perfectcorp.com
Japan (Shibadaimon 116 Bldg. 3F, 1-16-3, Shibadaimon, Minato-ku, Tokyo 105-0012) Whenever it happens (real-time transfer), data transferred via App Personal details, Demographic information, Expertise Contact details, Consent records, Purchase details, Data relating to our Sites and Apps, Employer details Content and advertising data, Views and opinions Providing Services and Recruitment on our Sites and Apps Only for as long as we maintain an ongoing relationship with you or your Personal Data are necessary in connection with the lawful purposes, plus any applicable limitation period under applicable law and an additional two (2) month period. In addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.
Perfect Corp.
privacyteam@perfectcorp.com
US (3031 Tisch Way, 110 Plaza West, San Jose, CA 95128) Whenever it happens (real-time transfer), data transferred via App Personal details, Demographic information, Expertise Contact details, Consent records, Purchase details, Data relating to our Sites and Apps, Employer details Content and advertising data, Views and opinions Providing Services and Recruitment on our Sites and Apps Only for as long as we maintain an ongoing relationship with you or your Personal Data are necessary in connection with the lawful purposes, plus any applicable limitation period under applicable law and an additional two (2) month period. In addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.
Perfect Corp.
privacyteam@perfectcorp.com
EU (55 Boulevard Pereire 75017 Paris) Whenever it happens (real-time transfer), data transferred via App Personal details, Demographic information, Expertise Contact details, Consent records, Purchase details, Data relating to our Sites and Apps, Employer details Content and advertising data, Views and opinions Providing Services and Recruitment on our Sites and Apps Only for as long as we maintain an ongoing relationship with you or your Personal Data are necessary in connection with the lawful purposes, plus any applicable limitation period under applicable law and an additional two (2) month period. In addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

8.3 For user in South Korea, you can withdraw your consent to let us transferring your data internationally. However, your service may be limited if you choose to withdraw your consent.

9 Data security

9.1 We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

9.2 Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

10 Data accuracy

10.1 We take every reasonable step to ensure that:

10.2 From time to time we may ask you to confirm the accuracy of your Personal Data.

11 Data minimisation

11.1 We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.

12 Data retention

12.1 We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:

12.2 During the periods noted in Section 12.1.2, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

12.3 Once the periods in Section 12.1, each to the extent applicable, have concluded, we will either:

13 Terms of Service

13.1 All use of our Sites, Apps, or Services is subject to our Terms of Service. We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

14 Direct marketing

14.1 We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, Apps, or Services that may be of interest to you. We also Process Personal Data for the purposes of displaying content tailored to your use of our Sites, Apps, or Services. If we provide Sites, Apps, or Services to you, we may send or display information to you regarding our Sites, Apps, or Services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

14.2 You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send. Please note that it may take up to 2 weeks to process your unsubscribe request during which time you may continue to receive communications from us. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, Apps, or Services you have requested.

15 Details of Controllers

15.1 For the purposes of this Notice, the entity and contact details of relevant Controllers are:

15.2 Alternatively, you may contact us using our online Contact Us page.

16 Analytics and Tailored Advertising

16.1 When you visit a Site or use an App we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We Process Personal Data through Cookies and similar technologies, in accordance with applicable laws.

16.2 Certain Cookies may be stored on your machine by third parties when you use our Sites. We have no control over these Cookies or how the third parties use them. These Cookies allow third parties to provide us with a service, for example, analytics about the effectiveness of our marketing activities and user behavior.

16.3 The following is a list of our current third party advertising partners linked to their privacy policies: Facebook, Google, Smaato, PubMatic, Index Exchange, Magnite (Rubicon), OpenX, applovin, aarki, liftoff, unrulyx, fluct, Inmobi and Chocolate Platform.

16.4 You may opt-out of targeted advertising utilizing the Digital Advertising Alliance ("DAA") AdChoices Program at optout.aboutadsinfo. For more information on the DAA AdChoices Program at visi youradchoices.com.In addition, the Network Advertising Initiative ("NAI") has developed a tool that allows consumers to opt out of certain Tailored Advertising delivered by NAI members' advertising networks. To learn more about opting out of such targeted advertising or to use the NAI tool, see https://optout.networkadvertising.org/.

16.5 You may also set your browser to block all cookies, including cookies associated with our Service, or to indicate when a cookie is being set by us. However, it's important to remember that many of our Service may not function properly if your cookies are disabled. For example, we may not remember your language preferences. Most web browsers automatically accept cookies but provide controls that allow you to turn off, block or delete them. Learn more at https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en

16.6 Please be aware that if you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, will be deleted and may need to be recreated

17 Do Not Track

17.1 Most browsers can be set to send signals to third party websites requesting them not to track the user's activities. At this time, we do not respond to "do not track" signals. Consequently, third parties may indeed track and collect information about your online activities over time while navigating to, from and on our online Services, notwithstanding any "do not track" signals we may receive.

18 Your legal rights in certain jurisdictions

18.1 General Data Protection Regulation (GDPR).

18.2 Illinois Biometric Information Privacy Act (BIPA). We may collect and process your biometric information for the purpose of providing personalized Services. We do not and will not use facial recognition or identification technology in providing our Services. Under BIPA, we must inform you of how we collect and process Biometric Information (as defined under BIPA) as a result of the Services we provide to you, namely the AR and AI features.

18.3 California Consumer Privacy Act Disclosures (CCPA). Under the California Consumer Privacy Act ("CCPA"), we must disclose our practices regarding the collection, use, and disclosure of the Personal Information of California Residents ("Consumers"). Consumers are also afforded additional rights with regard to the Personal Information we collect about them that include the rights of access, deletion, and to be free from discrimination. If you are a Consumer, the CCPA grants you the following rights regarding your Personal Information. Generally, in order to verify your requests to exercise your rights, we will compare the personal information we have about you to pieces of personal information we will request in the course of processing your request. The personal information required for verification may include your name, email address, phone number, or postal address. We will deliver a response to you within 45 days of receiving your verifiable consumer request. To exercise your rights under the CCPA, please follow the instructions described in this section.

18.4 California's "Shine the Light" Law. Under California's "Shine the Light" law, California residents are entitled to ask us for a notice describing what categories of personal customer information Perfect Corp. shares with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident, and would like a copy of this notice, please submit a written request to privacyteam@perfectcorp.com.

19 Contact Us

If you have questions or concerns with respect to our Privacy Policy, you may contact us at privacyteam@perfectcorp.com.

20 Definitions

20.1 "App" means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means).

20.2 "Adequate Jurisdiction" means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.

20.3 "Biometric Information" includes both "biometric identifiers" and "biometric information" as defined in the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq. "Biometric identifier" means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. "Biometric information" means any information, regardless of how it is captured, converted, stored, or shared, based on an individual's biometric identifier used to identify an individual.

20.4 "California Resident" means (1) every individual who is in the State of California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the State of California who is outside the state for a temporary or transitory purpose.

20.5 "Cookie" means a small file that is placed on your device when you visit a website (including our Sites). In this Notice, a reference to a "Cookie" includes analogous technologies such as web beacons and clear GIFs.

20.6 "Controller" means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.

20.7 "Data Protection Authority" means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.

20.8 "EEA" means the European Economic Area.

20.9 "GDPR" means the General Data Protection Regulation (EU) 2016/679.

20.10 "Personal Data" means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

20.11 "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household:

20.12 "Process", "Processing" or "Processed" means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

20.13 "Processor" means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

20.14 "Relevant Personal Data" means Personal Data in respect of which we are the Controller.

20.15 "Sell" means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to another business or a third party for monetary or other valuable consideration. A business does not sell personal information when:

20.16 "Sensitive Personal Data" means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, biometric data, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under applicable law.

20.17 "Services" means any and all services we provide, including (but not limited to) services relating to our Apps, Sites, products or services, and similar items from our licensors and other third parties.

20.18 "Site" means any website operated, or maintained, by us or on our behalf.

YOU UNDERSTAND AND AGREE THAT, BY ENTERING INTO THIS PRIVACY POLICY, YOU WAIVE THE RIGHT TO GO TO COURT OR TO PARTICIPATE IN A CLASS OR REPRESENTATIVE ACTION.