PRIVACY POLICY

Last updated: May 11, 2025

Your privacy is important to us, and we are committed to protecting your personal information. Opuliss Beauty, LLC is a luxury skincare and cosmetics brand
specializing in high-quality, cruelty-free, vegan, paraben-free products manufactured in Canada and designed to enhance the confidence and wellbeing of individuals across all skin types, tones, and identities.

This privacy policy (“Policy”)
complies with applicable U.S. and Canadian privacy laws, including the Personal
Information Protection and Electronic Documents Act (PIPEDA), and relates to
our use of your personal information when you interact with us through:

• our websites, microsites, or mobile applications;
• AI skin analysis and personalization tools;
• virtual try-ons and interactive technology;
• purchases through our websites;
• participation in promotional campaigns, surveys, or product reviews;
• social media interactions or marketing platforms;
• customer service communications; and/or
• any other online or offline engagement with Opuliss Beauty, LLC (collectively, the “Services”).

This Policy explains who we are, what personal information we collect about
you, how we use it (including who we share it with), and your rights and choices
regarding your personal information. By using our Services, you agree to the
terms of this Policy. If you do not agree, you should not use our Services.

Notice to California Residents : If you are a resident of California, you may
have additional rights regarding your personal information as set forth in the
“Additional Disclosures for California Residents” section below.
This website is not directed to or meant for use by residents of the United Kingdom, France, Germany, or other European Union countries. If you are a resident
of these jurisdictions, please visit our jurisdiction-specific websites.
If you have any questions or concerns about our use of your personal information, please contact our privacy officer at info@opuliss.com as detailed in the
section titled “How Do I Contact Opuliss Beauty?”

1. What Information Does Opuliss Beauty Collect About Me
and Why?

We collect various categories of personal information to fulfill your orders, personalize your experience, comply with legal obligations, and improve our Services. The information we collect falls into three primary categories:
1.1 Information You Provide Directly
When you engage with Opuliss Beauty, LLC, we may ask you to share personal
information. Below are the categories of personal information we may collect:
• Identifiers: Such as a real name, alias, postal address, unique personal
identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers. For example, if you create an account, purchase products, submit a product review, enter a competition, or
contact our customer service team, you may provide your first name, last
name, date of birth (optional), gender identity (optional), email address,
mailing address, telephone number, skincare concerns, or product preferences. When you register for an account, we may also collect information
associated with your account, such as the date you joined and your order
numbers.
• Personal Information Categories Listed in the California Customer Records
Statute: Such as name, signature, physical characteristics or description,
delivery address, billing address, telephone number, passport number, driver’s
license or state identification card number, insurance policy number, education, employment, employment history, payment card number, or any
other financial information. Some personal information in this category
may overlap with other categories.
• Images and Photographs: For example, if you submit content such as reviews, testimonials, or photographs, or engage with technologies like virtual try-ons, AI skin analysis, or other tools, we may collect and store those
materials along with metadata such as time and location. These tools do
not retain facial scans or biometric identifiers in a manner that violates
applicable law.
• Your Opinions or Other Information: For example, if you review products purchased from us or provide information about skincare concerns,
product preferences, or the brands and products you use.
• Protected Classification Characteristics Under California or Federal Law:
Such as age (40 years or older), sex (including gender, gender identity, gender expression, sexual orientation), veteran, or military status.
• Commercial Information: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
1.2 Information We Collect Automatically
When you engage with Opuliss Beauty, LLC, we may use cookies, web beacons,
and similar tracking technologies to collect the following information automatically (see our cookies policy for more details):
• Internet or Other Electronic Network Activity Information: Such as
browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement. For example, when you
visit the website, engage with Opuliss content, or interact with us digitally,
we may collect information from your device (e.g., computer, tablet, or mobile phone), such as your IP address, browser type, operating system, device type, unique device identification numbers, referring URLs, and time
zone settings.
• We may also collect information about how your device interacts with us,
including page views, session duration, links clicked, navigation patterns
(e.g., scrolling, clicks, and time spent on pages), preferences, viewed or
searched products/services, and data on crashes, download errors, and response times.
• Geolocation Data: Such as physical location or movements. We collect
your IP address and infer broad geographic location, such as city or postcode, therefrom. For example, when you visit the website or engage with
Opuliss content digitally, we may collect your country or city-level location.
• Inferences Drawn from Other Personal Information: Such as a profile
reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. For
example, we may use the above information to provide tailored advertising, content, and products we think you may like, as described in the section
“How Does Opuliss Beauty Use My Personal Information?”.
1.3 Information We Obtain from Third-Party Sources
From time to time, we may receive personal information about you from thirdparty sources, but only where we have confirmed that these parties have your
consent or are legally permitted to disclose it. Types of information include:
• Social Media Partners: For example, if you log in to the website using a
social media account or use features like “like” or “share” buttons, the social media site may share information such as your user ID, name, email
address, location, demographic data, interest profiles, or other data permitted under their privacy policy.
• Retailers, Distributors, and Third-Party Brand Partners: Where permitted by law and, if applicable, with your consent, these partners may share
information such as your first name, last name, email address, postal address, phone number, gender, browsing patterns, geolocation, device identifiers, click-through data, purchase behavior, or aggregated analytics tied
to your account or device.
• Technology Partners and Market Research Organizations: Where permitted by law and with your consent, these partners may share information such as browser patterns, geolocation, device identifiers, or inferred
preferences.

2. How Does Opuliss Beauty Use My Personal Information?

We use your personal information for the following legitimate business purposes:
• To Provide Products and Services: To fulfill orders, manage customer accounts, confirm orders, manage deliveries, and provide customer service,
including internal accounting and administration purposes.
• To Process Payments: After placing an order, your payment is processed
by third-party payment providers (e.g., Shopify, PayPal), who collect and
process your information per their privacy policies.
• To Verify Identity: For example, we may use your email address to check
if you have an existing account.
• For Analytics Purposes: We may analyze your information (e.g., location,
products/services requested, age, IP address, browsing behavior) to generate statistics, develop marketing plans, improve services, and aggregate/deidentify data for sharing with affiliates and partners. We use third-party
analytics providers to collect usage data, including demographics and interests, without linking it to your personally identifiable information.
• For Marketing Communications: If you opt in, we may use your information to send updates about products, services, surveys, exclusive offers,
product drops, events, sweepstakes, contests, or promotions via newsletters, emails, or SMS. Opt-out details are in the section “How Do I Stop Receiving Marketing Communications?”.
• For Tailored Advertising: We or third-party vendors (e.g., Meta, Google)
may use your information for contextual or behavioral advertising on thirdparty sites, including social media. You can manage cookie preferences or
opt out via third-party sites’ settings.
• For SMS Communications: If you opt in for text messages, we collect your
phone number and related data. See our terms of use for opt-out instructions.
• For Non-Marketing Communications: To communicate about accountrelated or service-related matters (e.g., identity verification, password resets, service updates, or purchase confirmations).
• To Provide Customer Service: To process and respond to inquiries or provide personalized product recommendations through AI-driven tools.
• For Site Optimization and Management: To administer the website, ensure security, customize experiences, improve functionality, fix operational
issues (e.g., crashes, bugs), and provide partner services.
• For Enhanced Viewing: To provide short video clips of products using
your IP address.
• For Product and Business Development: To improve products, develop  new offerings, and refine AI personalization tools without automated decisionmaking that produces legal or significant effects.
• For Fraud Prevention and Legal Protection: To detect fraud and protect
the rights and property of Opuliss Beauty, LLC, our employees, and business
partners.
• For Employment Applications: To consider you for job opportunities if
you contact us regarding employment prospects.
Use of Non-Personally Identifiable Information: We may use anonymized or
aggregated data to improve services, develop features, conduct research, understand usage patterns, resolve disputes, troubleshoot issues, fulfill requests, or
ensure security and compliance. Such data is not linked to individual users.
Change of Purpose: We will only use your personal information for the purposes for which it was collected unless we reasonably consider another compatible purpose. We will notify you and explain any unrelated purpose. We may
process your information without consent where permitted by law.

3. What Is Our Legal Basis for Processing Your Personal Information?

We rely on the following legal bases to collect and process your personal information under U.S. and Canadian law:

• Consent: When you sign up for marketing emails, participate in promotions, or use AI personalization tools. You may withdraw consent at any
time without affecting prior processing.
• Performance of a Contract: To fulfill obligations under a contract (e.g.,
processing purchases, managing accounts, or responding to service requests).
• Compliance with Legal Obligations: To meet legal requirements (e.g., maintaining financial records, identity verification, or responding to lawful requests under U.S. or Canadian law).
• Legitimate Interests: To operate the website, improve products/services,
offer relevant recommendations, prevent fraud, or analyze trends, where
not overridden by your rights.
• Vital Interests: To protect your or another person’s vital interests.
You are not always required to provide requested information, but this may limit
access to certain services. Mandatory fields are clearly marked. If we collect
information to comply with legal or contractual obligations, we will clarify this
and note consequences of non-provision.

4. Does Opuliss Beauty Share My Personal Information with
Anyone?

Opuliss Beauty, LLC does not sell your personal information. However, we may
have disclosed the following categories of personal information in the past 12
months to:

• Affiliates: To provide products/services as described in this Policy.
• Third Parties for Marketing: With your express consent, for promotional
purposes.
• Service Providers and Business Partners: For functions like e-commerce
processing (e.g., Shopify), payment processing, advertising (e.g., Meta, Google),
data management, analytics, AI services, customer support, and fulfillment.
This includes Canadian-based fulfillment partners for shipping products
manufactured in Canada. These providers are contractually obligated to
protect your information and use it only per our instructions.
• Business Transfers: To buyers in divestitures, mergers, acquisitions, or
similar transactions, subject to this Policy.
• Legal Compliance: To law enforcement, regulators, courts, or other parties in the U.S. or Canada where necessary to comply with law, establish
legal rights, or protect vital interests.
• With Your Consent: To other parties as permitted.

5. What Are My Data Protection Choices and Rights?

We respect your right to control your personal information. You may decline to
provide non-essential information, though this may limit service access. We aim
to keep your information accurate and encourage you to update contact details
by contacting our privacy officer at info@opuliss.com.
• Access: In some jurisdictions, including Canada and certain U.S. states, you
can request access to your personal information, subject to identity verification.
• Correction and Deletion: You may correct inaccurate information or request deletion, though exceptions apply (e.g., for legal or contractual obligations under U.S. or Canadian law).
• Do Not Track: We do not respond to Do Not Track signals unless required
by law.
6. What If I Access a Third-Party Site Through the Website?
The website may link to third-party sites. We are not responsible for their privacy practices, and this Policy applies only to our data collection. Review thirdparty privacy policies before engaging.

7. What If I Access or Use a Social Network or Public Forum
Through the Website?

Our website may enable access to social sites (e.g., Facebook, Instagram, Twitter).
We do not control these services, and their privacy policies apply. You may:
• Access social sites (e.g., YouTube videos or social plug-ins for comments,
shares, or likes).
• Submit content to public forums (e.g., reviews, forums, photographs), which
may be collected by us or others. We encourage avoiding personal information in public forums.
• Accept cookies (e.g., Facebook pixels) to track activity and show relevant
Opuliss content.
• Sign in using social accounts, sharing data like usernames or social media
handles per their policies.
We may use your information to identify you on social sites for relevant ads.
Social sites delete matching data promptly after processing.

8. How Do I Stop Receiving Marketing Communications?

We send marketing communications only with consent or as permitted by U.S.
or Canadian law. Opt out by clicking “unsubscribe” in emails, texting STOP for
SMS, or contacting our privacy officer at info@opuliss.com. Service-related communications (e.g., order confirmations) will continue.

9. How Long Does Opuliss Beauty Keep My Personal Information?

We retain personal information for ongoing business needs (e.g., providing services, fulfilling orders, or meeting legal, tax, or accounting requirements in the
U.S. or Canada). When no longer needed, we delete or anonymize it, or securely
store it until deletion is possible.

10. Does Opuliss Beauty Transfer My Personal Information to
Other Countries?

We may transfer and process your personal information between Canada and
the United States to provide our Services, as our products are manufactured and
shipped from Canada while our operations are headquartered in the U.S. We implement appropriate safeguards to ensure your information remains protected
in accordance with this Policy and Canadian privacy laws, such as PIPEDA. These
safeguards include contractual agreements with service providers to maintain
equivalent protection. Contact our privacy officer at info@opuliss.com for details.

11. Is My Personal Information Secure?

We implement appropriate technical, organizational, and physical safeguards to
protect your personal information from unauthorized access, use, or disclosure,
in compliance with U.S. and Canadian privacy standards. However, no electronic
transmission is entirely secure, and we cannot guarantee absolute security.

12. Contests, Promotions, or Surveys

Promotions may use your personal information as described or notified. Thirdparty policies may apply. Check terms, conditions, and policies before participating.

13. Age Requirements

You must be 13 or older to use our website or Services. In certain Canadian
provinces (e.g., British Columbia, New Brunswick, Newfoundland and Labrador),
users under 19 may require parental consent for data collection. We do not
knowingly collect data from children under 13 (or under 19 without consent
where applicable). If we become aware of such data, we will attempt to remove
it. California minors under 18 may request removal of public content by contacting our privacy officer at info@opuliss.com, subject to exceptions (e.g., legal
requirements or anonymized data).

14. Policy Updates

We may update this Policy due to legal, technical, or business changes, obtaining
consent where required by U.S. or Canadian law. We will notify you of changes
by posting the updated Policy or via email, updating the “Last Updated” date.

15. How Do I Contact Opuliss Beauty?

For questions, comments, or privacy requests, please contact our privacy officer
at:
• Email: info@opuliss.com
• Website: Via our contact form, selecting “Data Privacy” for privacy-related
requests.

16. Additional Disclosures for California Residents

Under the California Consumer Privacy Act (CCPA), California residents have
specific rights:

16.1 Use of Personal Information
We use or disclose personal information for purposes in this Policy and will not
use it for materially different, unrelated, or incompatible purposes without notice.
16.2 Share and/or Sale of Personal Information
See the sharing section above. Certain activities (e.g., sharing with advertising
partners) may be considered a “sale” under California law. Opt out by contacting
our privacy officer at info@opuliss.com or via our website’s contact form (select
“Data Privacy”). We do not knowingly sell data of those under 16.
16.3 Your Rights and Choices
• Right to Access and Data Portability: Request details about our collection
and use of your personal information over the past 12 months, including
categories, sources, purposes, third parties, and specific data.
• Right to Delete: Request deletion of your personal information, subject to
exceptions (e.g., for legal or contractual obligations).
16.4 Exercising Your Rights
Submit a verifiable consumer request by:
• Emailing info@opuliss.com with “Data Privacy Request” in the subject line.
• Completing our website’s contact form, selecting “Data Privacy”.
Only you or an authorized agent registered with the California Secretary of State
may request. Provide sufficient details for verification (e.g., account details or
interaction history). You may request access or data portability twice within 12
months. We respond within 45 days (up to 90 with notice), delivering responses
electronically. For data portability, we provide a readily usable format. We may
deny requests if we cannot verify identity or if exceptions apply, explaining reasons. No fee is charged unless requests are excessive, repetitive, or unfounded,
in which case we provide a cost estimate.
16.5 Non-Discrimination
We will not discriminate against you for exercising CCPA rights.
16.6 California Shine the Light Law
Under California Civil Code Section 1798.83, you may request a list of third parties receiving personal information for direct marketing annually. Contact our
privacy officer at info@opuliss.com with “California Privacy Rights” in the subject line.
16.7 Contact Information
For questions or comments about this Policy or your CCPA rights, contact our
privacy officer at:
• Email: info@opuliss.com
• Website: Via our contact form, selecting “Data Privacy”.