Last updated: 21 March 2024

Introduction

When you interact with WeAreEves, you trust us with (processing) your personal data, and we are committed to maintaining that trust. Being transparent is a priority for WeAreEves, and this privacy notice outlines how we process personal data which can help you make informed privacy decisions.

This statement outlines WeAreEves’s key data protection obligations. It does not attempt to cover all its data processing operations. More detailed information can be provided upon request. 

Definitions

 WeAreEves is an Interactive Platform: a cloud-based multi-device open marketplace shopping platform which is designed for users to place honest beauty product reviews on to help other users find what is right for them.  

WeAreEves B.V.: WeAreEves B.V is, a limited liability company incorporated under the laws of the Netherlands. The company is registered with the Dutch Chamber of Commerce under registration number 68732465 The company’s registered office is at Weesperstraat 61, 1018 VN, Amsterdam, The Netherlands. 

GDPR: the regulation of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation). 

User: a private person making use of our website 

Brand: a brand making use of our website services

Overview

Types of data we collect from you:

• User registration details: email, birthdate, name, country, product preferences, profile information, public profile information on social networks
• Contact details – i.e., first name, last name, postal address, date of birth, email address, telephone number
• Financial information if applicable (mainly partners for invoices)– i.e., payment information (credit/debit card details)
• Data that identifies you – i.e., online identifiers such as IP address, login information, location data, device type, device ID, fingerprint, browser type and version, cookies and similar technologies
• Demographic information and interests – i.e., age, gender or education
• Community data – i.e., comments, photos, videos and other content or information you choose to publish publicly
• Sensitive data – Eye colour, skin tone, skin type, hair type – for which we ask your explicit consent when signing up before collecting such data (please see this document and the terms & conditions for more information).
• Hair, Skin and Body issues for which you may or may not use certain cosmetic products to match you to products or users with the same

We collect data for the following:

• Authenticating members who sign in online 
• For the deregistering of users from the platform
• To respond to user requests, questions for contact
• To research and analyse our product platform performance- user engagement, platform activities
• Another purpose of processing your data is to help develop and improve our products and services in order to be of service to you and to innovate
• Collect information about a user for personalized content, including a user's activities, interests, visits to sites or apps, demographic information or location, to create or edit a user profile for use in personalizing content.

Information that is obtained from other sources:

We may receive information about you from other sources, for example:

• Information from Social Media Platforms such as your username, user ID, and demographic information, subject to the settings and privacy practices of the relevant Social Media Platform
• URL referral from another website/social media channel
• App information - Browser behaviour for A/B testing and optimisation purposes

How and why we use your personal data:

We need to have and process your personal data if you want to become a user of our platform, or if you want to contact us. Basically, we process your data to enter into a business relationship and agreement with you. We may also use your contact details to communicate with you. If you opt in for this, we will send newsletters to the email address you provided us with. 

In order for us to provide our services it’s necessary to process your personal data for above-mentioned purposes which are explained below. Next to that we always ask for your explicit consent when signing up as a user and as a tester, but also before you submit any content created by yourself about a product.[DD1] [QM2] 

• To fulfil our contractual obligation:
  • Product testing:
    • If you place an order with us or if you are a registered product tester, we will use your data for the purposes of processing your transaction in order to provide you with the requested products or services (i.e., using personal data to send shipments and to update you on their progress)
  • Keeping WeAreEves running:
    • Managing your requests (e.g. inviting users, connecting your account to other services)
    • Login and authentication, remembering your settings and preferences, processing payments
  • To protect our rights and rights of others:
    • Carry out fraud detection and prevention
• Legitimate interest
  • Marketing:
    • Sending you emails and messages about new features, products and services, and content (i.e., inviting users to attend events when required)[BK3] [DD4] 
    • Sending content about products or brands based on your interests as inferred from your activities over time
    • Sending product review testing round information
  • Improving WeAreEves:
    • Provide customer assistance or technical support
    • To improve our services and performance that we use to protect our network
    • To update our services based on your interests, participations and communities
    • To address any questions or concerns you raise to us about WeAreEves
    • Interacting with feedback platforms and questionnaires, conducting data analysis and research
    • To help develop and improve our products and services in order to be of service to you and to innovate.
  • For automated individual decision-making, including profiling
    • By profiling we mean any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a user, in particular to analyse or predict aspects concerning that user’s personal preferences, interests, behaviour or location. We use general profiling and decision-making based on profiling after you have given us your consent. You have the right to express your point of view and contest the decision.
    • We process your personal data to recommend reviews and products based on the profile and activities from other members with similar profile as yours.

Our legal basis for using your personal data:

• Contractual obligation:
  • For example, when you purchase a product from us, we process your data as necessary to provide you with the products/services you request.
•  Legitimate interests:
  • For example, we will process your personal data to perform our services and to make improvements on how you interact with us. 
• Legal obligation:
  • We will process your personal information to comply with legal requirements under applicable law
• Your consent:
  • For example, we may collect personal data through voluntary surveys. Responses to such surveys are collected based on consent. You can withdraw your consent at any time by contacting us at the details provided in the ‘Contact Us’ section below
• In order to match the reviews and products as well as possible, we process your skin type and other sensitive data. Within the meaning of the GDPR, this personal data is considered as special categories of personal data. For this, we need your explicit consent. We will never use this data for other purposes. You can withdraw your consent at any time by deleting your account or by contacting us at the details provided in the ‘Contact Us’ section below.

Data sharing with third parties and international data transfer:

In certain circumstances we may share information with third parties. Mainly for us to be able to carry out our service, we make use of a number of third parties. It is possible that your personal data will be stored, with your permission, with one of these partners. Naturally, WeAreEves has made agreements with these parties on how your personal data must be handled. These agreements are laid down in data processor agreements. Which and how many partners are involved will depend on the service WeAreEves provides for you, but these will be partners in the following categories:

• Brands
• We share data of our users with brands we work with for product testing and review purposes.
• We share data of our users with our partners so they can send out the orders (shipments) they place on our website for them to fulfil the order in their warehouses, also so they can send out tracking information and provide product updates.
• Service providers:
• We engage various third parties to provide services on our behalf. These providers can be requested upon request.
• Our service providers use the information we provide to them as necessary or appropriate for the performance of their services
• Advertisers & marketing related partners:
• If you have given consent, we may provide your information to entities for the purposes of delivering advertising aligned to products and services that may be of interest to you. For example, we share your e-mail address with Facebook for retargeting purposes. We only do this if you have given us consent to do so when signing up..
• Business partners:
• In certain circumstances, we provide your information to business partners for various reasons. For example, partnering with a third party for events or programs such as WeAreEves BV Eves Tester Program
• Other parties when required by law:
• We may share your information as we believe is necessary or appropriate to protect, enforce, or defend our legal rights
• Corporate transactions:
• If Eves BV is sold or integrated with another business, your personal information is disclosed to consultants of Eves BV and any advisers to the potential buyer
• With your consent:
• We share your information with third parties when you consent to or request such sharing

With third parties that process your data in our accord, we conclude a Data Processing Agreement (DPA) to ensure the same level of security and confidentiality of your data. WeAreEves remains responsible for these processing operations. 

In some cases we transfer your data to third parties outside the European Union and we take additional measures (such as Standard Contractual Clauses) to protect your data. In some countries outside the European Union, the rules for protecting your data are different from those that apply within Europe. If we make use of a third party located outside the European Union whereby your personal data is transferred to an international jurisdiction, we will ensure that adequate safeguards are in place for the security of your personal data. For more information on these safeguards, please contact us at the details provided in the ‘Contact Us’ section below.

Do we use automated individual decision-making, including profiling? 

By profiling we mean any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a user, in particular to analyse or predict aspects concerning that user’s personal preferences, interests, behaviour or location. We use general profiling and decision-making based on profiling after you have given us your consent. You have the right to express your point of view and contest the decision. 

Please note, by creating an account on WeAreEves, you agree to the sharing of your account username, photos, reviews, tips and videos with beauty brands for use in or on their communications and webpages. The same accounts for online content publishers. WeAreEves will not modify the content of the reviews. WeAreEves may choose to not show pictures that are uploaded with the review. Should a user not wish to have content shared with any other party then they should not place content on this website. WeAreEves is not liable for any content/opinion placed on its website by the community about any brand.

If a user creates content on the WeAreEves website, it grants WeAreEves the right to share this content with brands/3^rd parties that it works with at any time who may use this for internal or external purposes. Should a user not wish to have content shared with any other party, then they should refrain from placing content on this website. Users of the platform will always be asked for their explicit consent.

How long do we keep your data?

We will retain your personal information for as long as we have a relationship with you. Once our relationship with you comes to an end, we will retain your data:

• For the purposes of legal proceedings
• To comply with record retention requirements under applicable laws or other legal/statutory requirements
• To conduct fraud prevention/detection

We will delete your personal information when it is no longer required for these purposes.

Your privacy rights: 

• Right to access –
  • You have the right to ask us for a copy of your personal information.  
  • The categories of data we’re processing
  • The purposes of data processing
  • The categories of third parties to whom the data may be disclosed
  • How long the data will be stored (or the criteria used to determine that period)
  • Your other rights regarding our use of your data
• Right to erasure –
  • You have the right to ask us to erase your personal information
  • You can view, edit or delete your personal data by logging in to your personal account. If you have problems with viewing, editing or deleting your personal data, please send us an e-mail via info@weareeves.com 
  • If you make a request as described above, we will respond no later than one month after we received your request. 
• Right to objection –
  • You have the right to object to certain types of processing such as direct marketing
• Right to rectification –
  • You have the right to ask us to rectify information that is inaccurate or incomplete
• Right to portability –
  • You have the right to have the data we hold about you transferred to another organisation. If you ask us and it is technically possible, we will directly transfer the data to another service for you
•  Right to not to be subject to automated profiling and decision making –
  • You also have the right not to be subject to the legal effects of automated processing or profiling
• Right to complain to a supervisory authority –
  • You have the right to lodge a complaint to a supervisory authority, please tell us first, so we have a chance to address your concerns. If we fail in this, you can address your complaint to a supervisory authority

We will not discriminate against you for the exercise of these rights. Providing your personal data for survey, marketing and other profiling purposes as above specified is optional. Refusal to provide your personal data for these purposes will not have any impact on the entering into or performance of the contract.

Since WeAreEves relies on your consent to process your personal data, you have the right to withdraw such consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, WeAreEves may not be able to provide certain services to you.  

If you wish to exercise any of these rights, please contact the DPO using the contact details below.

Storage periods 

We do not store your data longer than necessary for the purpose of the processing, according to article 5 of the GDPR. 

Minors 

We do not consciously process personal data of minors without permission of a parent or guardian. If personal data of a minor is processed without permission, we will erase the data after taking knowledge of the fact. 

How do we use cookies? 

Cookie page : https://weareeves.com/en-NL/cookies

How do we use device fingerprinting?

Device fingerprinting is the collection of a variety of data about your device. This data is used to generate a unique “fingerprint” for the device.

These bits of information include operating system information, browser versions, and plugins being used, time zone location, IP addresses, and other related characters of the device.

When the fingerprint has been generated, WeAreEves is not able to see from which data this fingerprint was generated. WeAreEves does not store any of the characteristics of your device while creating this fingerprint.

Technical security

We work hard to protect your personal data against loss or any form of unlawful processing. We have taken appropriate technical and organizational measures to protect your personal data. WeAreEves reports any abuse or attempted abuse. In addition, we take technical and organisational measures in order to secure personal data against unauthorised access.

Please note, these rights are subject to applicable law. You can exercise your rights by contacting us at the details provided below

Contact us

For any data privacy and security questions you may have please contact our Data Protection Officer via DPO@weareeves.com.

Physical Address:

WeAreEves (Capital C - Ground floor)

Weesperstraat 61, 1018 VN Amsterdam, The Netherlands

Updates to this notice:

WeAreEves keep its privacy statement under regular review and reserves the right to change its statements from time to time at its sole discretion. If we make any changes, we will upload the new version and update the ‘last updated’ date. However, if we make relevant changes to this privacy notice, we will notify you by means of a prominent notice on the website prior to the change becoming effective. We will as well notify you of these changes by email.

We encourage you to check for updates to this privacy statement on a regular basis.