Privacy Policy

This Privacy Policy was updated on January 20, 2022.

KLUIA LLC (“we,” or “us”) provides this Privacy Policy to explain our practices regarding the collection, use, disclosure, and protection of information that apply to our Service, as well as your choices regarding the collection and use of information. This Privacy Policy covers our businesses including the websites that we own or maintain including without limitation www.kluia.co and www.karenalleluia.com and any other websites we may acquire or maintain. You understand and agree that any information you provide may be used in connection with any Site we own or maintain.

This Privacy Policy does not apply to information we collect by means (including offline) or from other sources other than through the Service or Our Site. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Use.

Information Collection and Use

Personally Identifiable Information:
We collect information regarding its current, prospective, and former clients, customers, users, visitors, guests, and Employees (“Personally Identifiable Information”) only when you provide such information directly to us in connection with the Service.

Information we may collect from you.
We ask for Personally Identifiable Information such as your name and e-mail address when you register for a customer account with the Service, (including by “following,” “liking,” adding a KLUIA LLC application, linking your account to a KLUIA LLC service, etc., on a third party website or network) or if you correspond with us (in which case we will also retain our responses). We may also collect demographic information, such as your age, gender, beauty product preferences, and interests. If you purchase products or services or sign up for a paid subscription, then we will also ask for additional information, such as your credit card number and billing address. We may also retain any messages you send through the Service, and may collect information you provide in User Content you post to the Service.

When you use the Services or engage in certain activities, such as registering for an Account, making an online or in-store purchase, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:

    • Creating an Account with Us. When you make a purchase online, we will automatically create an Account for you. To create an Account, we’ll collect certain information that can be used to identify you, such as your name, postal address and phone number, as well as other optional information you may provide like the type of clothing you prefer. If you create an Account using your login credentials from one of your third-party services accounts such as Facebook or Google (each an “Third-Party Account”), we’ll be able to access and collect your name and email address and other Personal Information that your privacy settings on the Third-Party Account permit us to access. If you create an Account through the Site or one of your Social Networking Services (“SNS”) Accounts, we may also collect your gender or date of birth.

    • Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, create an account, register for our newsletters or a loyalty program that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.

    • Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or services and in any manner consistent with the policies provided herein.

    • Registration for Sweepstakes or Contests. Occasionally, we may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. All sweepstakes/contests entry forms will provide a way for participants to opt-out of any communications that are not related to awarding prizes.

    • Automatic Data Collection. Our servers automatically record certain information about how Individuals use our Services (we refer to this information as “Event Data”). Event Data may include information such as an Individual’s Internet Protocol (IP) address, cookie identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, operating system, browser type and language, hardware type, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Event Data to administer the Services and we analyze (and may engage third parties to analyze) Event Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to Individuals’ needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how our Services are used.

    • Location Information. We may collect and store information about your location by converting your IP address into a rough geo-location. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.

    • Information Submitted Via Services. You agree that we are free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. We will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.

  • Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Services through a Third-Party application, such as an App Store or SNS, we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.

Uses made of the information.

We use Personally Identifiable Information to communicate directly with you. We may send you emails containing newsletters, promotions and special offers. We also use your Personally Identifiable Information to send you Service-related emails (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). You may not opt out of Service-related e-mails. We acquire, hold, use, and process Personal Information about Individuals for a variety of business purposes, including:

  • To Provide Products, Services, or Information Requested. We may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:

    • Generally manage Individual information and Accounts;

    • Respond to questions, comments, and other requests;

    • Provide access to certain areas, functionalities, and features of our Services;

    • Contact you to answer requests for customer support or technical support;

    • Allow you to register for events.

  • Administrative Purposes. We may use Personal Information about you for its administrative purposes, including to:

    • Measure interest in our products and Services;

    • Develop new products and Services;

    • Ensure internal quality control;

    • Verify Individual identity;

    • Communicate about Individual Accounts and activities on our Services and systems, and, in our discretion, changes to any of our policies;

    • Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;

    • Process payment for products or services purchased;

    • Process applications and transactions;

    • Prevent potentially prohibited or illegal activities;

    • Enforce our Terms.

  • Marketing Our Products and Services. We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:

    • To tailor content, advertisements, and offers;

    • To notify you about offers, products, and services that may be of interest to you;

    • To provide Services to you and our sponsors;

    • For other purposes disclosed at the time that Individuals provide Personal Information; or

    • Otherwise with your consent.

You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described below.

  • Research and Development. We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling and other similar purposes. We may contract with third parties who provide us with other information about you, which we may then combine with the information we receive from you. We use this information to better provide our Services, to customize our advertisements to you and other customers, and to provide direct marketing to you, including by mail.

From time to time, we may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.

    • Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on our or our business partners’ products and services or upcoming special offers/events we believe may be of interest.

    • Services via Mobile Devices. From time to time, we may provide Services that are specifically designed to be compatible and used on mobile devices. We will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of our Services may require that users log in with an Account. In such cases, information about use of mobile versions of the Services may be associated with Accounts. In addition, we may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to us to enable Individuals to access Accounts and to enable us to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. We may use personal or non-identifiable information transmitted to us to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices we provide.

    • Anonymous and Aggregated Information Use. us may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within our company and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

    • Sharing Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we allow you to provide information about your friends through our referral services, such as “Invite a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by us or any other Third Parties for any other purpose.

    • Other Uses. We may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

  • If you choose to use our invitation service to invite a third party to the Service, we will ask you for that person’s email address and automatically send an email invitation to the invitee. KLUIA LLC stores this information to send this email, to register the invitee if your invitation is accepted, and to track the success of our invitation service. Unless the invitee becomes a registered user of the Service, KLUIA LLC does not use the invitee’s email address for marketing purposes, and does not share the invitee’s email address with third parties other than KLUIA LLC’s service providers. The invitee may contact us at any time to request that we remove his or her information from our database at hello [at] kluia [dot] co.

Non-Personally Identifiable Information:
We also collect and use information about your interactions with the Service in a manner and format that does not identify you as an individual (“Non-Personally Identifiable Information”). We may collect, use, and disclose Non-Personally Identifiable Information as set forth below.

Analytics Information.
We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser as part of a web page request, including the web pages you visit, your browser add-ons, your browser’s width and height, and other information that assists us in improving the Service. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.

Cookies Information:
When you visit the Service, we may send one or more cookies - a small text file containing a string of alphanumeric characters - to your computer that uniquely identifies your browser and lets KLUIA LLC help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.

Log File Information:
Log file information is automatically reported by your browser each time you access a web page. When you use the Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.

Clear Gifs/Web Beacons Information:
When you use the Service, we may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.

Uses made of the information.
We use or may use cookies, log file, and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information; (c) monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses; (f) help you efficiently access your information after you sign in; and (h) track User Content and Users to the extent necessary to comply as a service provider with the Digital Millennium Copyright Act; (i) serve Online Advertising (please see below) to your browser or device, and (j) automatically update a Company application on your system and related devices. For more information on our practices with respect to User Content that you may post to the Service, please visit our Terms of Use.

Sharing of Your Information

Personally Identifiable Information:
We will not rent or sell your Personally Identifiable Information to third parties outside KLUIA LLC and its controlled subsidiaries and affiliates without your consent, except as noted below:

We may share your Personally Identifiable Information with third-party business partners for the purpose of providing the Service to you. Those business partners will be given limited access to the Personally Identifiable Information that is reasonably necessary to deliver the Service, and we will require that such third parties comply with this Privacy Policy.

Any Personally Identifiable Information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public, as controlled by any applicable privacy settings. To change your privacy settings on the Service please access your customer account page. If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information.

We may at any time buy or sell/divest the company, or any combination of its products, services, assets and/or businesses. Personally Identifiable Information such as customer names and email addresses, and other user information related to the Service will likely be one of the items transferred in these types of transactions. We may also transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions or similar transactions or proceedings.

KLUIA LLC will disclose Personally Identifiable Information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) conform to the law, comply with legal process served on us or our affiliates, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Use, take precautions against liability, to investigate and defend ourselves against any claims or allegations, to assist government enforcement agencies, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property, or personal safety of KLUIA LLC, our Users or others.

Non-Personally Identifiable Information:
We may share Non-Personally Identifiable Information, including information obtained through tools such as cookies, log files and clear gifs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with our third-party business partners for the purposes described in the section above on “Information Collection and Use.”

Online Advertising:
We may also share Non-Personally Identifiable Information with our business partners to deliver online advertisements (“ads”) that may be of interest to you. KLUIA LLC may allow third-party ad servers or ad networks to serve advertisements on the Service. These third-party ad servers or ad networks use technology to send, directly to your browser or mobile device, the ads and ad links that appear on the Service. The ad-servers automatically receive your IP address when this happens. They may also use other technologies (such as cookies, JavaScript, and clear gifs) to compile information about your browser’s or device’s visits and usage patterns on the Service (without using any Personally Identifiable Information), and to measure the effectiveness of their ads and to personalize the advertising content. KLUIA LLC does not provide any Personally Identifiable Information to these third-party ad servers or ad networks without your consent. However, please note that if an advertiser asks KLUIA LLC to show an ad to a certain audience and you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach. The KLUIA LLC Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers. Please consult the respective privacy policies of such advertisers or contact such advertisers for more information.

How We Protect Your Information

Storage and Processing:
Personally Identifiable Information collected through the Service may be stored and processed in the United States or any other country in which KLUIA LLC or its subsidiaries, affiliates or service providers maintain facilities.

Safeguarding Measures:
KLUIA LLC uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of all information collected from through the Service. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from KLUIA LLC, at all times. Notwithstanding the foregoing measures, KLUIA LLC cannot ensure or warrant the security of any information you transmit to KLUIA LLC or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of KLUIA LLC’s distributors, such as social networks. KLUIA LLC is not responsible for the functionality or security measures of any third party.

Compromise of Information:
In the event that any information under our control is compromised as a result of a breach of security, KLUIA LLC will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised, in accordance with applicable law and through the notification procedures set forth in this Privacy Policy.

Your Choices About Your Information

Opting Out of Collection of Personally Identifiable Information:
You may, of course, decline to submit any Personally Identifiable Information through the Service, in which case the KLUIA LLC may not be able to provide certain services to you.

Modifying Your Account Information and Settings:
You may update your account information and email-communication preferences at any time by logging in to your customer account page or contacting us directly at hello@kluia.co. As noted above, you may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices).

Opting Out of Collection of Non-Personally Identifiable Information:
The only way to completely “opt out” of the collection of any information through cookies is to actively manage the settings on your browser. Please refer to your browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Note that disabling cookies on your browser prevents you from receiving the features available through the Service.

User-Generated Content:
Following termination or deactivation of your customer account, KLUIA LLC may retain your profile information and User Content for a commercially reasonable time for backup, archival, or audit purposes. Furthermore, KLUIA LLC may retain and continue to use indefinitely all information (including User Content) contained in your communications to other Users or posted to public or semi-public areas of the Service after termination or deactivation of your customer account.

Children's Privacy

We do not knowingly collect or solicit Personally Identifiable Information from anyone under the age of 13 or knowingly allow such persons to register. The Service and its content are not directed at children under the age of 13. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at info [at] mai [dot] com.

Links to Other Web Sites and Services

We are not responsible for the practices employed by websites or services linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. Please read over those rules and policies before proceeding.

Changes to Our Privacy Policy

At our sole discretion we may modify or update its Privacy Policy from time to time, and so you should review this Policy periodically. When we change the policy, we will update the ‘last modified’ date at the top of this Privacy Policy and where appropriate, notify you through our notification procedure as outline in the Terms of Use. Changes to this Privacy Policy are effective when they are posted on this page, so please check back often for updates.

How to Contact Us

If you have any questions about this Privacy Policy or the Service, please contact us at hello [at] kluia [dot] co.