Privacy Policy.

This Privacy Policy explains how Beautypass (“BP”) may collect, use, and disclose information we obtain through the Service. All other terms not defined herein will have the meanings set forth in the Agreement. When you visit the App, we and our third-party service providers receive and record information on our server logs from your browser, including your IP address, and from cookies and similar technology

Analytics and Attribution. Beautypass may use third-party analytics and attribution providers, including AppsFlyer, to measure app installations, account registrations, purchases, reservations, offer redemptions, and other interactions with the Service. These providers may collect and process information such as device identifiers, advertising identifiers, IP addresses, referral sources, campaign attribution data, and conversion events in order to measure the effectiveness of advertising campaigns, attribute app installs and user activity to marketing sources, prevent fraud, improve the Service, and analyze user engagement. Where required by applicable law or platform requirements, Beautypass will request your consent before permitting tracking or attribution activities that require such consent. You may manage or withdraw applicable permissions through your device settings.

“Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as: name, address, email address, or phone number, profile information, photographs, content you upload, social media profile information you choose to connect, and other information that you make publicly available through any social network or platform. We do not consider Personal Information to include information that has been anonymized so that it does not allow a third-party to easily identify a specific individual.

We collect information, including Personal Information, when you register to use the App, list your social networking credentials in your profile, use the App and communicate with us.

When you use or visit BP you provide us with two types of information: personal information you knowingly choose to disclose that is collected by us and Site use information collected by us as you interact with our Site. When you register with Beautypass, you provide us with relevant information, such as contact person, email address, telephone number, address and any other information that you provide to us.

When you visit the App, we and our third-party service providers receive and record information on our server logs from your browser, including your IP address, and from cookies and similar technology. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Service may not work properly.

We use session ID cookies to confirm that users are logged in. These cookies terminate once the user closes the browser. By default, we use a persistent cookie that stores your login ID (but not your password) to make it easier for you to login when you come back to Beautypass. You can remove or block this cookie using the settings in your browser if you want to disable this convenience feature. When you use Beautypass, you may set up your personal profile, send messages, perform searches and queries, form groups, set up events, add applications, and transmit information through various channels. We collect this information so that we can provide you the service and offer personalized features. When you update information, we usually keep a backup copy of the prior version for a reasonable period of time to enable reversion to the prior version of that information. You post Personal Information on the App at your own risk. Although we allow you to set options that limit access to your pages, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other members with whom you share your Personal Information. Therefore, we cannot and do not guarantee that Personal Information you post on the App will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the App/Site. You understand and acknowledge that, even after removal, copies of Personal Information may remain viewable in cached and archived pages or if other members have copied or stored your Personal Information. Any improper collection or misuse of information provided on Beautypass is a violation of our T&C and should be reported to info@beautypass.app. Beautypass App may also collect information about you from publicly available sources, connected social media platforms you authorize, and other users through operation of the Service (e.g., photo tags) in order to provide you with more useful information and a more personalized experience.

International Data Transfers Beautypass and its service providers may store and process personal data outside the European Economic Area (EEA). Where personal data is transferred outside the EEA, we apply the safeguards required by applicable data protection law. Information about the applicable safeguards, including how to obtain a copy where available, may be requested at legal@beautypass.app.

Member Visibility. Beautypass allows members to discover and connect with businesses in their market. Businesses can view member profiles and send personalized offers, but cannot see members' precise locations. Members can also see other members' ratings of businesses and profile photos of recent visitors to venues. Recent visitor visibility is enabled by default and can be turned off at any time under Settings > Privacy. When disabled, your profile photo will no longer appear in recent visitor displays, including previous visits. This setting does not affect the visibility of your ratings or your profile to businesses.

Personal information collection. If you register to use the Service, you must provide us with certain Personal Information, such as your name, photos, information about work engagement and work experience and email address. You also must provide us with a scanned copy of your driver’s license, passport or other similar documentation where reasonably required to verify identity, prevent fraud, maintain safety, or comply with applicable law. You may also provide other optional information. We collect personal information, including physical addresses, only when voluntarily provided by users for specific purposes such as collaborations requiring the shipment of physical goods by business partners. Users are not required to provide an address to access other app features.

Third-Party Data Providers: Beautypass may engage third-party service providers to supply us with publicly available data on users for purposes such as analytics, marketing, or improving our services. This data may include information obtained from social media platforms or other publicly accessible sources. While this data is obtained from publicly available sources, we treat it in accordance with this Privacy Policy and take measures to ensure its lawful and responsible use. Please note that our use of third-party data is subject to the terms and conditions of our agreements with these providers and their privacy policies. We seek to ensure that any third-party providers we engage are compliant with the General Data Protection Regulation (GDPR) to safeguard the privacy and rights of our users.

Disclosure of Address Data: Beautypass does not sell, rent, or share user address information with any third parties, except as necessary to facilitate collaborations (e.g., sharing with a business partner fulfilling a shipping request), with service providers acting on our behalf, or where required by law. Businesses receive this information only after users voluntarily provide their address when submitting a collaboration request.

Social Sign-On. We collect Personal Information from a social media website when you use your social media accounts to log into the Service. For example, when you log in with your Facebook, Instagram, or other social media accounts, we may collect the Personal Information you have made publicly available on Facebook, Instagram and/or other social media platforms of which you are a registered member, such as your name, profile picture. Only in case you specifically authorized the upload, we will also collect data and pictures and other multimedia contents you made available to us which may not be (fully or partly) publicly available in Social Network, such as private galleries and albums.

Using the Service. We collect information you post through the Service. For example, when you interact with us by sending an email or message, the Service will collect the information you provide in such communication, including any Personal Information.

Social Media Posts and Content. When you submit a social media post link to complete an Offer, Beautypass may use the link and associated content to verify your posting requirements and display the content to you and the participating business through reservation details and the Content page.

Making payments. When you make payments through the Service, you may need to provide Personal Information to our third-party service providers, such as your credit card number. Payment will be according to the trading terms of Stripe and may be made by debit or credit card. Beautypass does not store full payment card details except as provided by our payment processors.

Customer support. We may collect Personal Information through your communications with our customer-support team.

Location information. We may obtain information about your physical location when you use the Service, including the exact location and address of the BP Spot in which you are located and related information, such as by use of GPS and other location features in the device(s) through which you access the Service, or by inference from other information we collect (for example, your IP address indicates the general geographic region from which you are connecting to the Internet), subject to your device permissions where applicable. Cookies, automatic data collection, and related technologies. The Service collects and stores information that is generated automatically as you use it, including your preferences and anonymous usage statistics. By using the Service, you are authorizing us to gather, parse, and retain data related to the provision of the Service. We also use your device location to determine your market and connect you with businesses in that area. Businesses can view your profile and send personalized offers, but cannot access your precise device location.

We use information, including Personal Information, to: • facilitate, operate, maintain, protect, and improve our services; • communicate with you and other BP members; • process transactions and collaborations; • prevent fraud, abuse, and misuse; • comply with legal obligations; and • personalize features and user experience.

We may use aggregate information for lawful business purposes, including marketing, analytics, and service improvement. Internal and service-related usage. We use information, including Personal Information, for internal and service-related purposes and may provide it to third parties to allow us to facilitate the Service. We may use and retain any data we collect to provide, secure, and improve the Service. Communications. We may send emails to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, promotions, security alerts, or system maintenance.

Member Activity Visibility Beautypass may display a general indication of a member's recent activity to participating businesses, based on when the member last opened the App. This helps businesses identify active members and send relevant collaboration invitations. Businesses do not receive exact activity timestamps, specific actions, or detailed usage history. We process this information based on our legitimate interest in facilitating interactions between members and businesses, subject to applicable data protection rights.

Personal Information We collect information that identifies you as an individual, which may include: Your name, email address, phone number, and physical address. Your profile information, including photographs and descriptions. Social media account details.

Demographic Information We may also collect non-identifying demographic data, such as:

Gender, age, interests, and other information to enhance user experience. Location data from your device settings or IP address to suggest nearby venues and services.

Profile Picture Data We collect and process profile pictures submitted as part of your account creation. Profile pictures are used to: Personalize your profile within the Beautypass platform. Facilitate interactions with businesses and members. Verify your identity during offer redemptions at partner venues. Your profile picture is displayed on the in-app ticket shown to venue partners.

Retention and Sharing Profile pictures, including rejected photos, and facial measurements are stored securely by Beautypass. Rejected photos are not automatically deleted. Profile photos may be visible to other members and participating businesses as described in this Privacy Policy. Facial measurements are used internally for duplicate-account detection and are not shared with participating businesses.

Information Sharing We may share limited information with third parties when necessary to operate and improve the Beautypass platform. For example: • If a user is approved for a campaign, we may share their shipping information with your Shopify store to fulfill the offer • If a campaign is connected to a Shopify store, we retrieve order and tracking data to notify the user and activate campaign timelines • We do not sell personal data to third parties

Community Visibility Beautypass may display your profile photo among recent visitors to venues where you have redeemed an Offer. This information is visible only to members logged into the Beautypass App and is not publicly available. This feature is enabled by default. You can turn it off at any time under Settings > Privacy. Turning it off removes your profile photo from recent visitor displays, including previous visits. Businesses can continue to view reservations made at their own locations, regardless of this setting.

All data sharing is purpose-limited and privacy-aware.

Automated Photo Verification and Biometric Data Beautypass uses automated technology to review profile photos and ensure they meet our quality and photo standards. These checks detect faces and assess image quality and compliance with our requirements.

To prevent fraudulent or duplicate accounts, Beautypass also processes and stores facial measurements derived from submitted photos to compare individuals and identify potential duplicate accounts.

These processes are operated internally by Beautypass and do not involve external AI verification providers.

User Rights

You may update your profile picture anytime via account settings. However, maintaining a profile picture is a requirement for using Beautypass. If you wish to delete your profile picture, you must deactivate your account by contacting legal@beautypass.app.

Depending on applicable data protection laws, including the GDPR and CCPA, you may have the right to:

Access the personal data we hold about you.

Correct inaccurate personal data.

Request deletion of your personal data.

Restrict or object to certain processing of your personal data.

Receive your personal data in a portable format, where applicable.

Withdraw consent where processing is based on consent, without affecting the lawfulness of earlier processing.

Exercise rights concerning certain decisions made solely through automated processing, where applicable.

To exercise these rights, contact legal@beautypass.app. We may request additional information where reasonably necessary to verify your identity and will respond within the timeframes required by applicable law.

You also have the right to lodge a complaint with the Cyprus Commissioner for Personal Data Protection or another competent supervisory authority.

Use of Addresses: Beautypass collects and stores physical addresses solely to facilitate the shipping of products by business partners during collaborations. This occurs when users request products and businesses fulfill those requests by shipping items to the provided address. Beautypass does not use this information for any other purpose.

Screenshots and Screen Recording Activity To ensure compliance with our Terms of Service and maintain platform integrity, Beautypass may monitor limited device activity related to screenshots or screen recordings taken within the App. We do not access or store your personal photos or media; however, the App may detect when screenshots or recordings are initiated and may log metadata (e.g., time, screen name) solely for internal security, fraud prevention, and enforcement purposes.

This information is never shared with third parties and is used only in accordance with our internal enforcement policies.

Information We Collect via Shopify

If you use Beautypass in connection with your Shopify store, we may collect the following information through the Shopify API: • Store name and domain • Product catalog (titles, images, pricing) • Order details (non-sensitive) • Fulfillment and tracking information • Customer shipping details (only when a user claims an offer)

We collect this data solely to support collaboration fulfillment, update campaign progress, and improve your experience on the Beautypass platform.

We will use any documentation that you provide to us to verify your identity for that sole purpose. Marketing. We may use information, including Personal Information, to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you, to promote your image or to enhance our cooperation and the visibility of the App. Aggregate data. We may anonymize and aggregate data collected through the Service and use it for any purpose. We may share your information:   •  with our third-party service providers;   •  with other BP members to comply with legal obligations;   •  to protect and defend our rights and property and with your permission. We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission. We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of the Service. For example, when you make payments through the Service, we will share your credit card number with our third-party payment processor. Displaying to other members. The content you post to the App may be displayed on the App. Other member of BP will be able to see some information about you, such as your name, photos, your relationship with BP Spot, and other relevant information. We are not responsible for privacy practices of the other members who will view and use the posted information. Accordingly, we recommend that you carefully consider what you post to the Service before doing so to guard your anonymity and sensitive information. Social networking and other websites. The Service may allow you to share information, including Personal Information, with social networking platforms such as Facebook, Instagram and etc. We do not share your Personal Information with them unless you direct the Service to share it. Their use of the information will be governed by their privacy policies, and you may be able to modify your privacy settings on their websites. Marketing. We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission. We may allow access to other data collected by the Service to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you.

As required by law and similar disclosures. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; or protect yours', ours' or others' rights, property, or safety. Merger, sale, or other asset transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. The use of your Personal Information following any of the foregoing events should be governed by the provisions of this Privacy Policy in effect at the time such Personal Information was collected.

We may also disclose your Personal Information with your permission.

We do not accept liability for unintentional disclosure. Your account information is located on a secured server behind a firewall. When you enter sensitive information (such as credit card number or your password), we encrypt that information using secure socket layer technology. It is however each member's responsibility; to protect against unauthorized access to your details; to ensure against use by anyone else of the Beautypass service through the machine that member uses while they are logged on to the Beautypass service; to log off or exit from the Beautypass service when not using it; and to keep her/his password secret. Because email and instant messaging are not recognized as secure communications, we request that you not send private information to us by email or instant messaging services. If you have any questions about the security of Beautypass App form, please contact us at: info@beautypass.app.

By using the App or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on the App or sending an e-mail to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at: info@beautypass.app

Security Measures: Beautypass employs best industry practices to protect personal information, including encryption and secure storage protocols, to safeguard physical addresses. While no system can guarantee absolute security, Beautypass takes reasonable and appropriate steps to prevent unauthorized access, loss, or misuse of any personal data.

We do not knowingly collect information from persons under 18 and we do not want it. We will take steps to delete it if we learn we have collected it. We do not knowingly collect, maintain, or use Personal Information from persons under 18 years of age, and no part of the App is directed to persons under the age of 18. If you are under 18, please do not attempt to register in Beautypass or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 18 may provide any personal information to or on Beautypass. If you learn that your child has provided us with Personal Information without your consent, you may alert us at info@beautypass.app.

If we learn that we have collected any Personal Information from persons under 18, we will promptly take steps to delete such information and terminate the minor's account.

This Privacy Policy is designed to comply with Shopify’s App Store requirements and includes disclosures regarding our use of the Shopify API.

If Beautypass is involved in a merger, acquisition, asset sale, or other change of control, your personal information may be transferred to the acquiring entity. That entity will continue to process your data in accordance with this Privacy Policy, and we will take reasonable steps to ensure your privacy rights remain protected.

By choosing to visit the App/Site or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the Republic of Cyprus and the adjudication of any disputes arising in connection with Beautypass or our Service will be in accordance with the T&Cs. Your personal data may be processed in Cyprus and other countries where Beautypass or its service providers operate, as described in Section 1 (International Data Transfers) of this Privacy Policy. Such processing remains subject to applicable data protection laws. Changing, removing and updating your information or pose a question or suggestion and control over most personal information on Beautypass is readily available through the profile editing tools. You may request deletion of your account and associated personal data by contacting legal@beautypass.app. We will process your request without undue delay in accordance with applicable law. Certain information may be retained where required or permitted by law, including for compliance with legal obligations or the establishment, exercise, or defense of legal claims. Backup data will be deleted or overwritten in accordance with applicable retention procedures. If you would like to update or correct any information that you have provided to us through your use of the Service or otherwise, or if you have suggestions for improving this Privacy Policy, please send an e-mail to info@beautypass.app

Control Over Address Information: Users retain full control over their address information. They may access, update, or delete their address through their app profile page. If a user requests account deletion, all address information will be permanently removed in accordance with Beautypass’s data retention policy.

We retain your personal data only as long as necessary to fulfill the purposes described in this policy, including for legal, operational, or compliance reasons. You may request deletion of your data at any time by contacting legal@beautypass.app.

Applicable Data Protection Laws Beautypass is operated by Nomad Sync Ltd., a company established in Cyprus, European Union. Our processing of personal data is subject to applicable data protection laws, including the General Data Protection Regulation (GDPR).

The GDPR applies to personal data processed in the context of our European Union establishment, regardless of a member's country of residence.

Members may also have rights under other applicable privacy laws, including the California Consumer Privacy Act (CCPA), where its requirements apply. Information about exercising your data protection rights is provided in Section 2 of this Privacy Policy.

We may revise this Privacy Policy, so review it periodically. Posting of Revised Privacy Policy. We will post any adjustments to the Privacy Policy on this web page and app, and the revised version will be effective when it is posted. If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

New Uses of Personal Information. From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.