Privacy Policy

Last Modified: December 2021 

Gemini Beauty Products ("Company," "we," or “us”) respects your privacy and is committed to protecting it through our compliance with this “Privacy Policy.” Throughout this Privacy Policy, we refer to any person accessing or using these Platforms (as defined below) as “you,” or the “User.”

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the website WWW.GEMINIBEAUTYPRODUCTS.COM, the services, features, content, and any portals (a “Portal”) or applications (an “App”) offered by the Company (collectively our "Platforms") and our practices for collecting, using, maintaining, protecting and disclosing that information. 

This Privacy Policy applies to information we collect:

  • On or through these Platforms.

  • In email, text, and other electronic messages between you and these Platforms.

  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

It does not apply to information collected by:

  • Us offline or through any other means not listed above; or 

  • Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from, or on, the Platforms. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information (as defined below in INFORMATION WE COLLECT) and how we will treat it. If you do not agree with our policies and practices, your only choice is not to use our Platforms. By accessing or using our Platforms, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of the Platforms after we make changes is deemed to be your acceptance of those changes, so please check the Privacy Policy periodically for updates. 


The Company’s Privacy Assurance

  • We do not sell your Personal Information to any non-affiliated third parties.

  • We do not share your Personal Information with nonaffiliated third parties that would use it to contact you about their own products and services unless you have allowed us to do so and as permitted pursuant to a joint marketing agreement.

  • We require our employees to protect your Personal Information and keep it confidential.

  • We require persons or organizations that represent or assist us in serving you to keep your information confidential.



Our Platforms are not intended for children under 13 years of age. No one under the age of 13 may provide any Personal Information to the Company through the Platforms. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information through any of the Platforms’ features/functionality, make any purchases through the Platforms, use any of the interactive or public comment features that may be available on these Platforms, or provide any information about yourself to us, including your name, address, telephone number, and/or email address and/or any screen name or username you may use. If we learn that we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at



We collect several types of information from and about Users of our Platforms, including log data, device data, and Personal Information. 

Log Data

When you visit our Platforms, our servers may automatically log the standard data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details. 

Device Data

We may also automatically collect data about the device you’re using to access our Platforms. This data may include the device type, operating system, unique device identifiers, device settings, and location data. What we collect depends on the individual settings of your device and software. 

Personal Information

We may collect information from you while you use these Platforms, including:

  • By which you may be personally identified, such as your first and last name, postal address, email address, telephone number, date of birth, Social Security Number (“SSN”), credit card information, and other identifying information that you choose to share with us by which you may be contacted online or offline ("Personal Information"); and/or

  • That is about you but individually does not identify you, such as your annual revenue, gender, certain demographic information. This information is not considered Personal Information, as it is anonymized statistical data. 



We will process your Personal Information lawfully, fairly, and in a transparent manner. We collect and process information about you only where we have legal bases for doing so. These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:

  • You give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter); 

  • It’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);

  • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as to present the Platforms to you, for research and development, to market and promote our services, and to protect our legal rights and interests; or

  • We need to process your data to comply with a legal obligation.



You may choose to restrict the collection or use of your Personal Information. If you have previously agreed to us using your Personal Information for direct marketing purposes, you may change your mind at any time by contacting us by email at (but this will not affect any processing that has already taken place).  If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our Platforms or products and services.


Information We Collect Automatically

As you navigate through and interact with our Platforms, we may use automatic data collection technologies to collect certain information about your devices, browsing actions and patterns, as described above. The technologies we use for this automatic data collection may include cookies, flash cookies, or web beacons. For more information on these technologies, see our DATA COLLECTION POLICY below. The information we collect automatically is statistical data and does not include Personal Information, but we may maintain it for any of the reasons listed in HOW WE USE YOUR INFORMATION. 

Information You Provide Directly to Us

The information we collect on or through our Platforms may include:

  • Information that you provide by filling in forms on our Platforms. This includes information provided at the time of registering to use our Platforms or while purchasing products through the Platforms. We may also ask you for information  when you report a problem with our Platforms;

  • Records and copies of your correspondence (including email addresses), if you contact us;

  • Details of transactions you carry out through our Platforms; and/or

  • Your search queries on the Platforms.


Information Provided to Us by Third Parties

If we receive Personal Information about you from a third party (for example, our business partners, data brokers, or credit reporting agencies), we will protect it as set out in this Privacy Policy. If you are a third party providing Personal Information about somebody else, you represent and warrant that you have such person’s consent to provide the Personal Information to us.



By providing Personal Information to us, you consent to us collecting, holding, using and disclosing your Personal Information in accordance with this Privacy Policy.



The technologies we use for automatic data collection on these Platforms may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Platforms. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platforms;

  • Flash Cookies. Certain features of our Platforms may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Platforms. Flash cookies are not managed by the same browser settings as are used for browser cookies; and/or

  • Web Beacons. Pages of the Platforms, and our emails, may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count Users who have visited those pages, or opened an email, and for other related statistics (for example, recording the popularity of certain content on the Platforms and verifying system and server integrity). 



“Do Not Track” is a preference you can set your browser to let websites you visit know that you do not want them collecting certain information about you. We do not currently respond to, or honor, Do Not Track signals or requests from your browser.



Some content or applications, including advertisements, on the Platforms are served by third-parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies (alone or in conjunction with web beacons or other tracking technologies) to collect information about you when you use our Platforms. The information they collect may be associated with your Personal Information, or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. 

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.  



We collect information about your actual location when you use our Platforms. Location information may help us tailor our Services for you, for example, by notifying you of local events or offers in your area or to tell other users of the Platforms that you are nearby.

We use various technologies to obtain your location. Your location can be determined with varying degrees of accuracy by:

  • GPS

  • IP address

  • Sensor data from your device

  • Information about things near your device, such as Wi-Fi access points, cell towers, and Bluetooth-enabled devices

The types of location data we collect depend in part on your device and account settings. If you have “Background Location,” “Background App Refresh” or any similar background app settings turned on, the Platforms will, from time to time, tell us about your device’s location even if you are not directly interacting with the Platforms. You can avoid tracking when not directly interacting with the Platforms by turning these settings off. 



Our Platforms give you ability to upload images and other information from your device’s camera and photos, say for example when leaving a review, meaning we may request access to your device’s photo library. You are not required to grant us access to your device’s library, but you understand that by refusing access to the Platforms, some of the Platforms’s features may be limited. When you grant us access to your photo library, you enable us to access your photos, videos, and any metadata. Depending on your settings, you may also grant us permission to add photos, as well as read and write within your photo library. You can avoid this by updating your settings to reflect the level of permissions you would like granted to the Platforms. 


We may collect your information for a number of reasons, specifically:

  • To enable you to access and use our Platforms;

  • To enable you to customize or personalize your experience of our Platforms;

  • To contact and communicate with you;

  • To prevent fraud;

  • For internal record keeping and administrative purposes;

  • For analytics, market research, and business development, including to operate and improve our Platforms;

  • To offer additional benefits to you, including but not limited to sending promotional information about our products/services and/or facilitating competitions and/or giveaways;

  • To provide you with information about third parties and services that may be of interest to you;

  • To fulfill any other purpose for which your provide your information and consent; and/or

  • To comply with our legal obligations and resolve any disputes that we may have.

As stated above, we may use your information to contact you about our own and third-parties' services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (for example, the registration form), or adjust your User preferences in your account profile. 

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.


We disclose Personal Information that we collect or that you provide, as described in this Privacy Policy, in the following circumstances:

  • To our tutors, in order to offer and complete the services;

  • To our subsidiaries and affiliates;

  • To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them;

  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by the Company about our Platforms’ Users is among the assets transferred. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your Personal Information according to this Privacy Policy;

  • To fulfill the purpose for which you provide it;

  • For any other purpose disclosed by us when you provide the information; or

  • With your consent.



We may disclose your Personal Information to third party service providers for the purpose of enabling them to provide their services, if you have allowed us to do so, including but not limited to:

  • Information Technology (“IT”) service providers;

  • Data storage, hosting, and server providers;

  • Ad networks;

  • Analytics companies;

  • Error loggers;

  • Maintenance or problem-solving providers;

  • Marketing or advertising providers;

  • Professional advisors and payment systems operators; and/or

  • Sponsors or promoters of any competition or promotion we run.

We may also disclose your Personal Information to third parties for the purpose of establishing, exercising, or defending our legal rights, including but not limited to:

  • Debt collectors; 

  • Our legal counsel and/or prospective legal counsel; and/or

  • Courts, tribunals, regulatory authorities, and law enforcement officers, as required by law.

We may disclose aggregated, anonymized, statistical data and/or non-identifying information about our Users without restriction.



The Personal Information we collect is stored and processed where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your Personal Information, you consent to the disclosure to any overseas third parties.

We will ensure that any transfer of Personal Information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Where we transfer Personal Information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.



We strive to provide you with choices regarding the Personal Information you provide to us. The following mechanisms should help to provide you with control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of these Platforms may be inaccessible or not function properly.

  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by logging into the Platforms and adjusting your User preferences in your account profile by checking or unchecking the relevant boxes, or by sending us an email stating your request to

  • Promotional Offers from the Company/Affiliates. If you do not wish to have your email address/contact information used by the Company or its affiliates to promote our own or third parties' products or services,  you can opt-out by logging into the Platforms and adjusting your User preferences in your account profile by checking or unchecking the relevant boxes, or by sending us an email stating your request to If we have sent you a promotional email, you may use the unsubscribe option in the footer of the email. This opt out does not apply to information provided to the Company as a result of a product or service purchase, or other transactions.

We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.


If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you can review and change your Personal Information, and even delete it, by logging into your account profile on the Platforms and navigating to the appropriate settings page. You cannot delete some of your Personal Information except by also deleting your User account. We may not accommodate a request to change information if we believe the change would violate any law or regulatory requirement, result in fraud, or cause the information to be incorrect.


You may request a copy of the Personal Information we hold about you at Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the Personal Information we hold about you at any time. However, you understand that any erasure of Personal Information may affect our ability to provide our services, content, or the Platforms to you. You may also request that we transfer this Personal Information to another third party.



If you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of your Personal Information with third parties for their own direct marketing uses. California’s “Shine the Light” Act provides that you have the right to submit a request to us at our email address in order to receive information on the categories of customer information that we shared and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To obtain this information, please send an email message to with "Request for California Privacy Information" in the subject line and in the body of your message. We will provide the requested information to you in your email address in response.

Please be aware that not all information sharing is covered by the Shine the Light requirements, and only information on covered sharing will be included in our response.



We won’t keep Personal Information for longer than is necessary to present our Platforms to you or to provide our services to you. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. If necessary, we may retain your Personal Information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us through the Platforms is secured by TLS technology, and is stored on our secure, password protected servers behind firewalls. We have implemented a restricted employee access for all of our servers containing personally identifiable information. 

Any payment transactions will be encrypted using SSL technology. We use Stripe (PCI-DSS compliant) as our payment processor.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platforms, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Platforms. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platforms. 


We will comply with any laws applicable to us in respect of any data breach. 



It is our policy to post any changes we make to our Privacy Policy on this page, with a notice that the Privacy Policy has been updated on the Platforms’ home pages via pop-up window. If we make material changes to how we treat our Users' Personal Information, we will notify you by email to the most recent email address provided to the Company either through email correspondence or through your User account and/or through a notice on the Platforms’ home pages. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Platforms and this Privacy Policy to check for any changes.



If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint

To make a complaint, ask questions, or make a comment about this Privacy Policy and our privacy practices, contact us at:



Our Data Controller is Gemini Beauty Products and may be contacted at 

Our Data Protection Officer is Joann Zehenni for Gemini Beauty Products and may be contacted at