Match My Makeup App - Privacy Policy

Ivivaco Pty Ltd trading as Match My Makeup ("Match My Makeup", "MMM", "we", "us" or "our") respects your privacy and is committed to protecting the personal information you provide to us.

This Privacy Policy explains how we collect, use, disclose, store and protect personal information when you use the Match My Makeup mobile application, website and associated services ("MMM App").

This Privacy Policy should be read together with our Terms of Use.

1. Who We Are

Match My Makeup provides beauty technology designed to help users discover, organise and shop beauty inspiration and receive personalised beauty, colour, shade and product recommendations.

Ivivaco Pty Ltd trading as Match My Makeup

ABN: 38 638 638 874

Address: 1501a, Tower 1, 520 Oxford Street, Bondi Junction, NSW 2022, Australia

Privacy contact: appsupport@matchmymakeup.com

For the purposes of applicable data protection laws, including the UK General Data Protection Regulation ("UK GDPR"), Ivivaco Pty Ltd is the controller of the personal information described in this Privacy Policy unless otherwise stated.

The MMM App is offered to users in Australia, the United Kingdom and the United States.

Our representative in the United Kingdom for the purposes of Article 27 of the UK GDPR is:

REP27 LTD (company number 17385889), Unit 82a James Carter Road, Mildenhall, Suffolk IP28 7DE, United Kingdom. Data subjects in the United Kingdom may contact the representative at info@gdprrepresentative.com. Appointment verifiable at: https://gdprrepresentative.com/verify.php?code=UK27-7190-4CF:

EU representative under Article 27 GDPR: Europe Services, SE, Na Cecelicce 425/4, Smichov, 150 00 Praha 5, Czech Republic. Data subjects may contact the representative at info@gdprrepresentative.com regarding the processing of their personal data. Appointment verifiable at: https://gdprrepresentative.com/verify.php?code=R27-7190-4CF1

2. Information We Collect

The information we collect depends on how you use the MMM App and the features you choose to use.

2.1 Account Information

When you create an account, we may collect:

• your name;
• username;
• email address;
• password or authentication information;
• profile image;
• confirmation that you are at least 16;
• country or region; and
• account preferences.

2.2 Beauty Profile Information

To personalise your experience, you may provide information about your physical characteristics, beauty preferences and skin concerns.

This may include:

• skin depth or skin tone;
• skin undertone;
• eye colour;
• hair colour;
• skin age;
• visible skin concerns or characteristics, including hydration, fine lines and wrinkles, redness, acne or blemishes and pigmentation;
• makeup preferences;
• beauty preferences;
• products and shades you currently use;
• product and shade matches; and
• other information you choose to add to your Beauty Profile.

Some of this information may be entered by you directly. If you choose to use our optional Face Scan feature, some Beauty Profile information may instead be generated or inferred through analysis of your facial image.

Some information generated by a Face Scan, particularly information relating to your skin condition, may constitute health information or other sensitive or special-category personal data under applicable privacy laws.

We therefore provide additional information and request your express consent before you use Face Scan.

2.3 Location, Preferences and Public Profile

We may also collect:

• your location, which we work out approximately from your IP address and which you can also select yourself, so that we can show products, prices and retailers available where you are;
• your favourite brands and favourite creators; and
• information you add to your public profile, such as your handle, profile image, Creator Codes and the looks and Lookbooks you choose to make public.

Your handle, profile image, Creator Codes and the looks and Lookbooks you make public are visible to other users. Your Beauty Profile, Face Scan results, private Lookbooks, private photos and location are not shown publicly. Lookbooks are private by default.

3. Virtual Try-On

Match My Makeup provides Virtual Try-On ("VTO") functionality that allows you to visualise cosmetic products on your face using your device's camera.

How VTO works

VTO uses MediaPipe facial landmark technology to detect facial landmarks and generate a three-dimensional facial mesh.

The mesh enables cosmetic textures and effects to be positioned on the appropriate areas of your face, such as your eyes, lips, cheeks or complexion.

Your image remains in your browser

VTO processing takes place locally within your browser/device.

When you use VTO:

• your camera provides the image locally to the VTO technology;
• MediaPipe detects facial landmarks and generates the facial mesh locally;
• the mesh is used to position cosmetic textures on your face;
• MMM does not receive the camera image on its servers;
• MMM does not store the camera image on its servers; and
• MMM does not use the VTO facial mesh to identify or authenticate you.

The facial mesh is used only to provide the VTO experience and is not added to your Beauty Profile.

Your device or browser may separately request your permission before allowing the MMM App to access your camera.

4. Face Scan and AI Skin Analysis

MMM offers an optional Face Scan feature that analyses your facial image to help create or personalise your Beauty Profile.

You do not need to use the Face Scan to use the MMM App.

Where available, you may provide relevant Beauty Profile information manually instead.

4.1 How the Face Scan works

If you choose to use Face Scan:

• you will be asked to allow access to your device's camera;
• an image of your face is captured;
• the image is transmitted securely to MMM's server;
• MMM temporarily holds the image only for the purpose of conducting the analysis, for no longer than 1 minute.
• the image is transmitted to Google's Gemini service for AI analysis;
• Gemini analyses the image and returns structured information to MMM;
• MMM stores the resulting information against your Beauty Profile; and
• MMM does not retain the original facial image after the analysis process is completed, subject to any temporary technical processing described below.

4.2 Information generated from the Face Scan

The analysis may generate or infer information including:

• eye colour;
• hair colour;
• skin depth;
• skin age;
• hydration;
• visible fine lines and wrinkles;
• redness;
• acne or blemishes;
• pigmentation; and
• other visible skin characteristics supported by the feature.

These results are used to personalise your Beauty Profile and the beauty and product recommendations provided to you.

4.3 What we do not use Face Scan for

MMM does not use Face Scan for the purpose of:

• identifying who you are;
• verifying your identity;
• authenticating your account;
• recognising you when you return to the App;
• comparing your face against a database of individuals; or
• surveillance or facial recognition.

MMM does not store a facial recognition profile for these purposes.

4.4 Accuracy of Face Scan

AI-generated skin analysis is an estimate based on visible characteristics in the image.

Results can be affected by factors including lighting, camera quality, makeup, image quality and other environmental factors.

Face Scan is provided solely for cosmetic, beauty and product-personalisation purposes.

It is not a medical or dermatological assessment and does not diagnose, treat, prevent or monitor any disease, disorder or medical condition.

References to "skin concerns", "skin age", "acne", "redness", "hydration", "pigmentation", "wrinkles" or similar characteristics describe cosmetic observations generated by the feature and should not be interpreted as a medical diagnosis.

5. Consent for Face Scan and Sensitive Information

Before activating Face Scan, we will request your express consent to the collection and processing of your facial image and the sensitive information that may be generated or inferred from it.

You may decline to provide this consent and continue using other features of the MMM App.

Where we rely on your consent, you may withdraw that consent at any time.

Withdrawal does not affect the lawfulness of processing undertaken before you withdrew your consent.

You may also request deletion of Face Scan results stored in your Beauty Profile as described in section 16.

United States. If you live in Illinois, Texas, Washington, Nevada or another US state that regulates biometric information or consumer health data, before you use Face Scan we will tell you in writing what we collect, why and for how long, and we will obtain your written consent through the App. We will not sell, lease, trade or otherwise profit from your Face Scan image or results. Our retention and destruction schedule for Face Scan information is set out in section 15. If you live in Washington or Nevada, please also read our Consumer Health Data Privacy Policy.

6. User Content

You may choose to upload or create content within MMM, including:

• photographs;
• makeup looks;
• profile images;
• Lookbooks;
• captions;
• comments;
• product information;
• reviews or other content.

Where you make content public, it may be visible to other MMM users through Discovery, your profile or other public areas of the App.

Photos you upload from your device are stored by MMM so that you can access them. They are private unless you choose to make them public and are not analysed using AI. Instead, you can add the products you used yourself.

We process this information to provide the features you have selected and in accordance with our Terms of Use.

7. Third-Party Social Content

MMM allows users to save and discover links to publicly available beauty content hosted on third-party platforms such as Instagram, TikTok, Pinterest and YouTube.

For this content, MMM may process:

• the URL or content identifier;
• originating platform;
• publicly available creator handle;
• a thumbnail image of the content, which we store on our servers;
• associated MMM categories, tags or product information; and
• information about the MMM user who saved the content.

To identify the beauty products in a look, we process the video, images and audio of the third-party content. We use OpenAI and Groq to transcribe the audio and Gemini to analyse the images and video. This analysis is used only to identify beauty products. It does not analyse the creator’s skin, age or other personal characteristics and is not used to identify the creator. We store the resulting list of detected products.

If you are a creator whose content is referenced in MMM, this Privacy Policy explains how we handle the limited information about you described in this section, and you may exercise the rights described in section 16.

The underlying third-party video or other content remains hosted by the originating platform where applicable.

Clicking the relevant content will take you to the original content on the third-party platform.

MMM does not claim ownership of third-party content merely because it is linked or referenced within the App.

Creators or rights holders may request removal of links or previews relating to their content by contacting appsupport@matchmymakeup.com or using the reporting functionality within the App.

8. Lookbooks and Discovery

When you create a Lookbook, we collect information about the looks, products and content you choose to save and how you organise them.

Depending on the functionality you select, Lookbooks may be private or publicly visible.

We may also use your Beauty Profile, saved looks and interactions with MMM to determine which beauty looks, products or other content may be relevant to you.

9. Shopping and Affiliate Links

MMM may provide links to beauty brands, retailers and other third-party websites where products can be purchased.

We may record information such as:

• which products you view;
• which recommendations you receive;
• which shopping links you select; and
• conversion or transaction information made available to us by participating retailers or affiliate partners.

Some links are affiliate links. MMM may receive a commission if you purchase a product after following an affiliate link.

Links in the “Where to Buy” section may be provided through affiliate networks and programmes, including Skimlinks, Rakuten Advertising, Impact, Awin and Amazon Associates. Some links are not affiliate links. When you follow an affiliate link, the affiliate network and the retailer may receive information such as your IP address, device information and a click identifier, and may use cookies or similar technologies on their own websites under their own privacy policies.

Unless otherwise disclosed, MMM does not receive your complete payment card information where a purchase is completed directly with a third-party retailer.

If you display a Creator Code on your public profile, we process it to show it to other users.

10. Usage and Technical Information

When you use the App, we may automatically collect certain technical and usage information, such as:

• device type;
• operating system;
• browser type;
• IP address;
• App version;
• approximate location derived from IP address;
• session information;
• features used;
• pages or screens viewed;
• searches;
• interactions with recommendations;
• saved content;
• clicks; and
• diagnostic and performance information.

We use this information to operate, secure, analyse and improve the MMM App and understand how users interact with our services.

We use Sentry to collect crash and error reports. We do not show advertising in the App and do not use advertising trackers.

11. How We Use Personal Information

We may use your personal information to:

• create and manage your account;
• maintain your Beauty Profile;
• provide personalised shade, colour and product recommendations;
• provide Face Scan and skin analysis where you choose to use it;
• provide Virtual Try-On;
• personalise Discovery and other App experiences;
• enable you to create and manage Lookbooks;
• enable community and content features;
• provide product discovery and shopping functionality;
• operate affiliate links;
• communicate with you about your account and the App;
• provide customer support;
• maintain the security and integrity of the App;
• detect misuse, fraud and security incidents;
• analyse and improve the performance and usability of MMM;
• identify the beauty products shown in looks;
• detect AI-generated content and other content that may breach our Community Guidelines;
• comply with our legal obligations; and
• enforce our Terms of Use and Community Guidelines.

We do not use your Face Scan image or Face Scan results to train artificial intelligence models.

Marketing. We do not currently send marketing communications. If we do so in future, we will comply with applicable law, including by obtaining your consent where required, and every message will include a way to unsubscribe.

Automated decision-making. We use computer programs to generate your shade and product matches, to identify products in looks, to personalise Discovery and to help identify content that may breach our Community Guidelines. These programs use information in your Beauty Profile, your saved looks and your interactions with the App. We do not make decisions that have a legal or similarly significant effect on you solely by automated means, and decisions to suspend or terminate an account are reviewed by a person.

12. AI Service Providers

We use Google's Gemini AI models, through the paid Gemini API, to provide the Face Scan analysis.

When you use Face Scan, your facial image is transmitted to Gemini so that the AI system can analyse the image and return the requested skin and appearance information.

Google therefore processes the image on our behalf or in connection with providing this functionality.

MMM receives the results of that analysis in structured form and stores those results against your Beauty Profile.

We configure our Gemini service so that facial images submitted for Face Scan are not used by Google to train or improve its general AI models. Google may retain submitted information for a limited period, as stated in its Gemini API terms for paid services, for purposes such as abuse monitoring and legal compliance, after which it is deleted.

We use OpenAI to transcribe the audio of third-party content, and Gemini to analyse images and video of third-party content, so that we can identify the beauty products shown in a look (see section 7). Under our arrangements with them, OpenAI do not use this content to train their models and retain it only for a limited period for abuse monitoring or legal purposes.

We do not send Face Scan images to OpenAI, and we do not send photos you upload from your device to any AI service provider.

13. When We Share Personal Information

We may disclose personal information to service providers that assist us in operating the App, including providers of:

• cloud hosting;
• artificial intelligence and image analysis;
• authentication;
• transcription and image analysis;
• error monitoring;
• affiliate networks and retail partners;
• data storage;
• analytics;
• customer support;
• email and communications;
• security; and
• other technology infrastructure.

These providers, listed below, may process personal information only for the purposes for which we engage them, subject to applicable contractual and legal requirements.

We may also disclose information where:

• required or authorised by law;
• necessary to protect the rights, safety or security of MMM, our users or others;
• required in connection with a corporate transaction such as a merger, acquisition or sale of the business; or
• you have otherwise authorised the disclosure.

We do not sell your personal information and we do not share it for cross-context behavioural or targeted advertising. We do not sell, lease or trade your facial images or Face Scan information.

14. Overseas Disclosure and International Transfers

MMM operates internationally and uses service providers that may process information outside Australia.

This may include Google and other technology or infrastructure providers located in, or operating infrastructure in, other countries.

Where required by applicable law, we take steps to ensure that international transfers of personal information are subject to appropriate safeguards.

For users in the United Kingdom, this may include UK adequacy regulations (including the UK-US Data Bridge), the UK International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses.

The MMM App is hosted by Linode (Akamai) on servers in the United States (Fremont, California) and India. Our other key service providers, including Cloudflare, Google, OpenAI, Groq and Sentry, process information in the United States and may also process it in other countries where they operate. This means personal information of users in Australia and the United Kingdom is processed outside those countries.

15. How Long We Keep Information

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected or as required by law.

In particular:

VTO camera images: are processed locally in your browser/device and are not stored by MMM.

VTO facial mesh: is generated locally for the VTO experience and is not stored in your MMM Beauty Profile.

Face Scan image: is held temporarily for the time necessary to submit it for AI analysis and receive the result. MMM does not retain the original image after this process is complete, and in any event deletes it within 1 minute.

Face Scan results: are stored as part of your Beauty Profile until you delete the relevant information, delete your account, withdraw applicable consent and request deletion, or until we no longer reasonably require the information, subject to legal retention obligations.

In any event, we will permanently delete Face Scan results no later than three years after your last use of the App.

Third-party content: thumbnails and detected product lists are kept while the look remains in MMM, and are deleted when it is removed, including at the creator’s request.

Photos and other User Content: are kept until you delete them or your account, subject to section 22 of our Terms of Use.

Account information: is retained while your account remains active and for a reasonable period thereafter where necessary for legal, security or administrative purposes.

Backups may retain deleted information for a limited period before being overwritten or securely deleted.

16. Your Privacy Rights

Depending on where you live, you may have rights including the right to:

• access personal information we hold about you;
• correct inaccurate information;
• request deletion of your information;
• withdraw consent;
• object to or restrict certain processing;
• receive certain personal information in a portable format;
• complain about our handling of your information; and
• lodge a complaint with your local privacy or data protection regulator.

You may be able to update or delete certain Beauty Profile information directly through the App.

To exercise a privacy right, contact us at appsupport@matchmymakeup.com.

We may need to verify your identity before processing certain requests.

17. United Kingdom Users

Where the UK GDPR applies, MMM processes personal data under one or more lawful bases depending on the activity, including:

• performance of our contract with you where processing is necessary to provide the App;
• legitimate interests, including operating, securing and improving MMM, where those interests are not overridden by your rights;
• consent, where we ask you to make a choice about particular processing; and
• legal obligations where processing is required by law.

Where information generated by Face Scan constitutes special-category personal data, including health data, we rely on your consent (Article 6(1)(a)) and your explicit consent (Article 9(2)(a)), which we request separately before Face Scan processing occurs. We process third-party creator content to identify beauty products on the basis of our legitimate interests (Article 6(1)(f)).

18. United States Users

This section applies if you live in a US state with a comprehensive consumer privacy law, such as California, Colorado, Connecticut, Virginia, Texas or Oregon, and supplements the rest of this Privacy Policy. Some of these laws apply only to businesses that meet certain thresholds, but we have chosen to extend the rights below to all users in the United States.

Categories of personal information. We collect the following categories of personal information, from the sources and for the purposes described in sections 2 to 11: identifiers (such as name, username, email address and IP address); commercial information (such as products viewed and shopping links selected); internet or other electronic network activity; approximate geolocation; audio, electronic or visual information (such as photos and Face Scan images); inferences (such as your Beauty Profile and product matches); and sensitive personal information (such as account login credentials and Face Scan results that may reveal health information). We disclose these categories to the service providers described in section 13.

Sale and sharing. We do not sell your personal information and we do not share it for cross-context behavioural advertising or use it for targeted advertising. We do not knowingly sell or share the personal information of consumers under 16.

Sensitive personal information. We use sensitive personal information only to provide the features you request, to keep the App secure and for other purposes permitted by law, and not to infer characteristics about you beyond what those features require.

Your rights. Depending on your state, you may have the right to know about and access the personal information we hold about you, correct it, delete it, receive a portable copy, opt out of the sale or sharing of personal information, targeted advertising and certain profiling, and limit the use of sensitive personal information. To exercise these rights, contact appsupport@matchmymakeup.com. You may use an authorised agent. If we decline your request, you may appeal by replying to our decision, and if your appeal is refused you may contact your state Attorney General. We will not discriminate against you for exercising your rights.

Consumer health data. If you live in Washington or Nevada, please read our Consumer Health Data Privacy Policy, which explains how we handle Face Scan results and skin-concern information as consumer health data.

19. Children and Age Requirements

The MMM App is not intended for children below the minimum age specified in our Terms of Use.

Our minimum age is 16. We ask users to confirm that they are at least 16 when they create an account. If we learn that a user is under 16, we will close the account and delete their personal information, subject to any legal obligation to keep it.

We do not knowingly collect personal information from children below that age contrary to applicable law.

If we become aware that we have collected such information unlawfully, we will take reasonable steps to delete it.

20. Security

We implement reasonable technical and organisational measures designed to protect personal information against misuse, interference, loss, unauthorised access, modification and disclosure.

No electronic system or transmission is completely secure, and we cannot guarantee absolute security.

Given the sensitivity of Face Scan information, MMM applies additional controls to the transmission, temporary processing and storage of information associated with that feature.

21. Data Breaches

Where we become aware of a personal data breach, we will investigate and respond in accordance with applicable law, including notifying affected individuals and relevant regulators where required.

22. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

Where changes materially affect how we process your personal information, we will provide reasonable notice and, where required, obtain fresh consent.

The current version will always be available through the MMM App and our website.

23. Contact and Complaints

If you have a question, privacy request or complaint, please contact:

Privacy Officer Ivivaco Pty Ltd trading as Match My Makeup

Email: appsupport@matchmymakeup.com

Address: 1501a, Tower 1, 520 Oxford Street, Bondi Junction, NSW, 2022, Australia

UK representative: REP27 LTD (company number 17385889), Unit 82a James Carter Road, Mildenhall, Suffolk IP28 7DE, United Kingdom. Data subjects in the United Kingdom may contact the representative at info@gdprrepresentative.com. Appointment verifiable at: https://gdprrepresentative.com/verify.php?code=UK27-7190-4CF:

We will investigate privacy complaints and respond within a reasonable period.

Australian users may also contact the Office of the Australian Information Commissioner.

UK users may lodge a complaint with the Information Commissioner's Office.