Privacy policy.
PRIVACY POLICY
Last updated January 19, 2025
This privacy notice for Vitality Technology LLC (“we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you:
Download and use our mobile applications (Rehair, Gloh, Naly, Bonde), or any other application of ours that links to this privacy notice.
Engage with us in other related ways, including any sales, marketing, or events.
Questions or concerns?
Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at contact@vitalitytechnologyllc.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find more details about any of these topics by clicking the link following each key point or by reviewing the table of contents below.
What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us, the Services, and the choices you make. Learn more about personal information you disclose to us.
Do we process any sensitive personal information?
We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.
Do we receive any information from third parties?
We do not receive any information from third parties.
How do we process your information?
We process your information to provide, improve, and administer our Services, communicate with you, ensure security and fraud prevention, and comply with legal obligations. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which types of parties do we share personal information?
We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe?
We implement organizational and technical processes and procedures to protect your personal information. However, no electronic transmission over the internet or storage system can be guaranteed to be 100% secure. We cannot promise that hackers, cybercriminals, or unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights?
Depending on your location, applicable privacy laws may grant you certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights?
The easiest way to exercise your rights is by submitting a data subject access request or by contacting us at contact@vitalitytechnologyllc.com. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect?
Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. DO WE COLLECT INFORMATION FROM MINORS?
10. WHAT ARE YOUR PRIVACY RIGHTS?
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
14. DO WE MAKE UPDATES TO THIS NOTICE?
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you voluntarily provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or when you contact us directly.
Personal Information Provided by You.
The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
Selfies
Sensitive Information.
When necessary, with your consent or as otherwise permitted by applicable law, we may process the following categories of sensitive information:
Biometric data
Payment Data.
If you make purchases, we may collect data necessary to process your payment, such as your payment instrument number and the security code associated with your payment instrument. All payment data is stored by Apple, and you may find their privacy notice at:
https://www.apple.com/legal/applepayments/privacy-notice/
Application Data.
If you use our mobile applications (Rehair, Gloh, Naly, Bonde), we may also collect the following information if you choose to provide us with access or permission:
Mobile Device Access. We may request access or permission to certain features from your mobile device, including your device’s contacts, camera, and other features. You may change our access or permissions at any time in your device’s settings.
Push Notifications. We may request to send you push notifications regarding your account or certain features of the applications. If you wish to opt out from receiving these communications, you may turn them off in your device’s settings.
This information is primarily needed to maintain the security and operation of our applications, troubleshoot issues, and for our internal analytics and reporting purposes.
All personal information you provide must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (such as your name or contact information) but may include device and usage information, such as:
Your IP address
Browser and device characteristics
Operating system
Language preferences
Referring URLs
Device name
Country and location
Information about how and when you use our Services
This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
The information we collect includes:
Log and Usage Data. This includes service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services. Depending on how you interact with us, this log data may include:
Your IP address
Device information
Browser type and settings
Information about your activity within the Services (such as date/time stamps, pages and files viewed, searches, and other actions you take, such as feature usage)
Device event information (such as system activity, error reports – sometimes called “crash dumps,” and hardware settings)
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, enhance security and fraud prevention measures, and comply with legal obligations. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
To deliver and facilitate the provision of services. We may process your personal information to provide the features and functionalities of our Services to you.
To improve our Services. We process your data to better understand how our Services are used and to develop new features and improvements.
To respond to user inquiries and provide support. We may process your information to respond to your questions and address any issues related to our Services.
For security and fraud prevention. Your information may be processed to identify and prevent fraudulent transactions, monitor for suspicious activity, and ensure the security of our Services.
To comply with legal obligations. We may process your data to comply with applicable laws, regulations, and legal processes.
To personalize your experience. We may use your information to tailor your experience on our Services and to provide content and features relevant to your interests.
To enforce our terms and policies. Your information may be processed to ensure compliance with our legal terms, policies, and agreements.
To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we have a valid legal reason (i.e., legal basis) under applicable law, such as with your consent, to comply with laws, to provide our Services, to fulfill our contractual obligations, to protect your rights, or to meet our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
Under the General Data Protection Regulation (GDPR) and UK GDPR, we rely on the following legal bases to process your personal information:
Consent. We may process your personal information if you have provided explicit consent for us to do so for a specific purpose. You have the right to withdraw your consent at any time. Learn more about withdrawing your consent.
Legal Obligations. We may process your personal information when it is necessary to comply with our legal obligations, such as cooperating with law enforcement authorities, responding to legal claims, or fulfilling regulatory requirements.
Vital Interests. We may process your personal information if necessary to protect your vital interests or the vital interests of another individual, such as in emergency situations involving potential harm to a person’s health or safety.
Contractual Necessity. We may process your data to fulfill our contractual obligations to you or to take steps prior to entering into a contract with you.
Legitimate Interests. We may process your personal information when we believe it is necessary to achieve our legitimate business interests, such as improving our Services, marketing our products, and ensuring security.
If you are located in Canada, this section applies to you.
We may process your personal information if you have provided:
Express consent, meaning you have explicitly agreed to the processing of your personal information for a specific purpose.
Implied consent, meaning your permission can be reasonably inferred based on your actions or context.
You can withdraw your consent at any time.
In some exceptional cases, we may process your personal information without your consent when legally permitted under applicable Canadian laws, including but not limited to the following situations:
If the collection is clearly in the interests of an individual and consent cannot be obtained in a timely manner.
For fraud detection and prevention purposes.
For business transactions, provided certain legal conditions are met.
If it is necessary for assessing, processing, or settling an insurance claim.
For identifying injured, ill, or deceased individuals and communicating with next of kin.
If we have reasonable grounds to suspect that an individual has been, is, or may be a victim of financial abuse.
If obtaining consent would compromise the availability or accuracy of the information and it is collected for purposes of investigating a breach of an agreement or legal violation.
If disclosure is required to comply with a subpoena, warrant, court order, or applicable legal processes.
If the information was produced in the course of employment, business, or profession and its use is consistent with the purposes for which it was collected.
If the collection is solely for journalistic, artistic, or literary purposes.
If the information is publicly available and specified by Canadian regulations.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share your information in specific situations described in this section and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers
We may share your data with third-party vendors, service providers, contractors, or agents (“third parties“) who perform services for us or on our behalf and require access to such information to provide their services.
We have contracts in place with these third parties to help safeguard your personal information. These contracts specify that:
They may only process your personal information on our documented instructions.
They are prohibited from sharing your personal information with any organization other than us.
They must protect your data in accordance with applicable data protection laws.
They must retain your data only for the period instructed by us and no longer than one year, unless required by law.
The categories of third parties we may share personal information with include:
Data Analytics Services – to analyze trends and improve our Services.
Data Storage Service Providers – to securely store and manage collected information.
Other Situations Where We May Share Personal Information
We may also need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Legal Compliance. We may disclose your personal information to comply with applicable laws, enforce our policies, respond to legal requests, or protect our rights, property, or safety.
With Your Consent. We may share your information with third parties for other purposes with your explicit consent.
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services but are not affiliated with our Services.
The Services, including our offer wall, may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantees regarding any such third parties, and we are not responsible for any loss or damage that may result from your use of such third-party websites, services, or applications.
The inclusion of links to third-party websites, services, or applications does not imply an endorsement or approval by us. We cannot guarantee the safety and privacy of any data you provide to third parties. Any data collected by third parties is not covered by this privacy notice, and we encourage you to review their privacy policies and contact them directly with any questions.
We are not responsible for the content, privacy, or security practices of any third parties, including websites, services, or applications that may be linked to or from our Services. It is your responsibility to review the policies of such third parties before providing any personal information.
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by third parties with whom we share your personal information (see WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?), in the United States and other countries.
If you are a resident of the European Economic Area (EEA), United Kingdom (UK), or Switzerland, these countries may not have data protection laws as comprehensive as those in your country. However, we have taken necessary measures to protect your personal information in accordance with this privacy notice and applicable laws.
European Commission’s Standard Contractual Clauses:
To protect your personal information when it is transferred outside of the EEA, UK, or Switzerland, we have implemented the European Commission’s Standard Contractual Clauses (SCCs) for data transfers. These clauses require all recipients to protect personal data originating from the EEA and UK in accordance with European data protection laws and regulations.
Our Standard Contractual Clauses are available upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners, and further details can be provided upon request.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice, up to a maximum of one year, unless otherwise required by law.
We will retain your personal information only as long as necessary to provide you with access to your previous scan results and to fulfill the purposes outlined in this privacy notice. Specifically, we will retain your face scans for a maximum period of one year, unless a longer retention period is required or permitted by law.
Once we no longer have an ongoing legitimate business need to process your personal information, or after the one-year retention period has elapsed, we will delete or anonymize such information. If deletion is not feasible (for example, due to technical limitations), we will securely store your information and isolate it from further processing until deletion is possible.
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. These measures include, but are not limited to:
Encryption of sensitive data during storage and transmission.
Access controls to limit access to personal information to authorized personnel only.
Regular security assessments and monitoring for potential vulnerabilities.
Secure data storage practices to prevent unauthorized access.
However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. As such, we cannot guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security measures and improperly collect, access, steal, or modify your information.
While we strive to protect your personal information, the transmission of personal data to and from our Services is at your own risk. You should only access the Services within a secure environment and take necessary precautions to protect your devices and data.
9. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 years old or that you are the parent or legal guardian of a minor and consent to their use of the Services.
If we learn that we have collected personal information from users under 18 years of age without verified parental consent, we will deactivate the account and take reasonable steps to promptly delete such data from our records.
If you become aware of any data we may have collected from children under 18 years of age, please contact us at contact@vitalitytechnologyllc.com.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In certain regions (such as the EEA, UK, Switzerland, and Canada), data protection laws grant you specific rights regarding your personal information. These rights may include the ability to:
Request access and obtain a copy of your personal information.
Request rectification or erasure of your personal information.
Restrict the processing of your personal information.
Request data portability, where applicable.
Object to the processing of your personal information, in certain circumstances.
To exercise any of these rights, you can contact us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”. We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you have the right to lodge a complaint with your local data protection authority.
EEA Residents: You can find contact details for your local data protection authority here.
UK Residents: You can contact the UK Information Commissioner's Office (ICO) here.
Switzerland Residents: You may contact the Federal Data Protection and Information Commissioner here.
Withdrawing your consent:
If we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”.
Please note that withdrawing your consent will not affect the lawfulness of the processing conducted before your withdrawal, nor will it affect processing based on other lawful grounds where permitted by applicable law.
Opting out of marketing and promotional communications:
You can unsubscribe from our marketing and promotional communications at any time by:
Replying “STOP” or “UNSUBSCRIBE” to SMS messages that we send.
Contacting us via the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”.
After opting out, you will be removed from our marketing lists; however, we may still send you service-related communications, such as important account notifications or responses to service requests.
If you have any questions or comments about your privacy rights, you may email us at contact@vitalitytechnologyllc.com.
11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers, as well as some mobile operating systems and applications, include a Do-Not-Track (“DNT”) feature or setting that you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.
At this time, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.
If a standard for online tracking is adopted in the future that we are required to follow, we will update this privacy notice to reflect such changes and inform you accordingly.
12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you are granted specific rights regarding access to your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
Category
Examples
Collected
A. Identifiers
Contact details such as real name, alias, postal address, telephone or mobile number, unique personal identifier, online identifier, IP address, email address, and account name.
NO
B. Personal information as defined in the California Customer Records statute
Name, contact information, education, employment, employment history, and financial information.
YES
C. Protected classification characteristics under state or federal law
Gender and date of birth.
NO
D. Commercial information
Transaction information, purchase history, financial details, and payment information.
NO
E. Biometric information
Face scans and other biometric data.
YES
F. Internet or other similar network activity
Browsing history, search history, online behavior, interest data, and interactions with our Services.
NO
G. Geolocation data
Device location.
NO
H. Audio, electronic, visual, thermal, olfactory, or similar information
Images and audio, video, or call recordings created in connection with our business activities.
NO
I. Professional or employment-related information
Business contact details, job title, work history, and professional qualifications.
NO
J. Education information
Student records and directory information.
NO
K. Inferences drawn from personal information
Inferences about preferences, characteristics, and behaviors.
NO
L. Sensitive personal information
Biometric data such as face scans.
YES
We will retain the collected personal information as needed to provide the Services or for:
Category B – As long as the user has an account with us.
Category L – As long as the user has an account with us.
You have the right to limit the use or disclosure of your sensitive personal information.
How do we use and share your personal information?
Learn more about how we use your personal information in the section “HOW DO WE PROCESS YOUR INFORMATION?”.
We may disclose your personal information with our service providers pursuant to a written contract. Learn more in the section “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”.
We do not sell or share personal information to third parties for business or commercial purposes.
California Residents
California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our California users to request information regarding disclosure of their personal information to third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at contact@vitalitytechnologyllc.com.
If you are under 18 years of age, reside in California, and have a registered account with our Services, you have the right to request removal of any unwanted data you publicly post. To request data removal, contact us with the email associated with your account and a statement confirming you are a California resident.
CCPA Privacy Notice (California Consumer Privacy Act)
Under the California Consumer Privacy Act (CCPA), California residents have the following rights:
Right to Request Deletion of Data – Request that we delete your personal information, subject to legal exceptions.
Right to Be Informed – Request details about the collection and usage of your personal information.
Right to Non-Discrimination – We will not discriminate against you for exercising your rights.
Right to Opt-Out of Selling or Sharing Personal Information – We do not sell personal information.
Right to Limit Use of Sensitive Personal Information – You can request that we limit the use of your sensitive personal data.
To exercise these rights, email us at contact@vitalitytechnologyllc.com or submit a request through our website.
Rights for Residents of Colorado, Connecticut, Utah, and Virginia
Residents of these states are granted rights under their respective privacy laws, which may include:
Right to Access Personal Data – Request a copy of your personal data.
Right to Correction – Request correction of inaccurate data.
Right to Deletion – Request deletion of your personal information.
Right to Data Portability – Obtain a copy of your personal data in a portable format.
Right to Opt-Out – Opt out of targeted advertising, sale of data, or profiling.
To exercise your rights, contact us at contact@vitalitytechnologyllc.com or submit a request via our website.
If we deny your request, you may appeal by emailing us within the timeline specified by applicable state law.
Verification Process
To ensure your identity when processing requests, we may require additional information to verify your identity. Depending on your request, we may ask for proof of identity or use other verification methods. Any additional data collected for verification will be deleted once the request has been processed.
Other privacy rights:
You may object to the processing of your personal information.
You may request correction of inaccurate or outdated information.
You may designate an authorized agent to make requests on your behalf under applicable privacy laws.
To exercise these rights, please email contact@vitalitytechnologyllc.com or refer to the contact details below.
13. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You may have additional rights based on the country in which you reside.
Australia and New Zealand
We collect and process your personal information in accordance with the requirements set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020 (collectively, the "Privacy Acts").
This privacy notice satisfies the notice obligations defined in both Privacy Acts, including:
What personal information we collect from you.
The sources from which we collect your personal information.
The purposes for which we process your personal information.
The recipients of your personal information.
If you do not wish to provide the personal information necessary to fulfill the applicable purposes, this may impact our ability to:
Offer you the products or services you request.
Respond to or assist with your inquiries.
At any time, you have the right to request access to or correction of your personal information. To make such a request, please contact us using the details provided in the section “HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?”.
If you believe we are unlawfully processing your personal information, you have the right to file a complaint:
Australia: Contact the Office of the Australian Information Commissioner at www.oaic.gov.au.
New Zealand: Contact the Office of the New Zealand Privacy Commissioner at www.privacy.org.nz.
Republic of South Africa
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us using the details provided in the section “HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?”.
If you are unsatisfied with how we handle any complaints regarding your personal information, you may contact the Information Regulator of South Africa using the following details:
The Information Regulator (South Africa)
General inquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form 5):
PAIAComplaints@inforegulator.org.za
POPIAComplaints@inforegulator.org.za
14. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time to reflect changes in our practices, legal requirements, or other operational reasons. The updated version will be indicated by an updated “Revised” date, and the updated version will become effective as soon as it is accessible.
If we make material changes to this privacy notice, we will notify you by:
Posting a prominent notice on our Services.
Sending you a direct notification, where required by law.
We encourage you to review this privacy notice periodically to stay informed about how we are protecting your personal information.
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have any questions or comments about this privacy notice, you may contact us via email or postal mail at:
Vitality Technology LLC
Email: contact@vitalitytechnologyllc.com
Address:
Vitality Technology LLC
Brighton, MI 48116
United States
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, request changes to that information, or request deletion of your personal information.
To submit a request to review, update, or delete your personal information, please contact us via email at contact@vitalitytechnologyllc.com or by filling out and submitting a data subject access request form through our website.