MyRoutine AI Notice
La Roche-Posay, part of L’Oréal USA, Inc., has instituted the following Information Notice related to any personal information that La Roche-Posay may obtain, possess, use, process, transfer, or store about you (“You”) as a result of Your use of MyRoutine AI. For further information about La Roche-Posay’s privacy practices as they relate to this service or other personal information La Roche-Posay collects about You when You use our website or other La Roche-Posay services, please review La Roche-Posay’s Privacy Policy.
Purpose
The purpose of the collection, storage, processing, and use of personal information for MyRoutine AI is to provide You with a meaningful, efficient way to evaluate products for potential purchase and use. When You use La Roche-Posay’s MyRoutine AI, La Roche-Posay collects and processes certain data, see “How It Works,” infra, in order to deliver a better beauty experience to You. La Roche-Posay may use information about You to communicate with You about La Roche-Posay beauty products and services; answer questions; create better experiences; provide tailored advertising, content, services, recommendations, and communications; fulfill product purchases and process payments; analyze use of La Roche-Posay products and services, without any associated personal identification information of users, so as to improve effectiveness of La Roche-Posay’s Site, customer service, and offerings, including improvement of the virtual MyRoutine AI tool and underlying algorithm; conduct research, including high-level analytics without associated personal identification information; to comply with applicable laws or legal obligations; for corporate governance, including mergers, acquisitions, divestitures, and other corporate restructurings, and TO ENFORCE THE TERMS OF USE, which additionally govern and apply to Your use of MyRoutine AI.
How It Works
In order to use MyRoutine AI, You must upload an image or photograph of Yourself (a/k/a, a “selfie”). Your photograph will be transmitted from Your device to a central cloud-based hub, where it is analyzed. La Roche-Posay will use an algorithm to analyze the selfie to detect face landmarks to localize the region around key facial features (i.e., outline of eyes, lower part of nose, outline of lips, etc.). This information is used for visualization (e.g., present skin concern zones on the selfie) and to provide You with the requested service (e.g., analyze the correct areas of the face needed to identify skin concerns). It is not used to identify or verify the identity of any individual.
La Roche-Posay will use an additional and separate algorithm to analyze the selfie to calculate age, ethnicity, and assess signs of skin aging using multiple dimensions (e.g., location of wrinkles, redness, microvessels, cheek pores, pigmentation around eyes, UV damage, ptosis of lower face, density of pigmentation, etc.). The algorithm predicts ethnicity and age to provide you with more accurate results. For example, some signs of skin ageing are not analyzed depending on age, gender, and/or ethnicity, while detected age, gender, and/or ethnicity may impact calculated results. This information is used to calculate skin concerns (e.g., blotchiness, lack of radiance, size of pores, pigmentation, fine lines, firmness, depth of wrinkles, UV damage), which are used to provide you with results.
Based on results of the foregoing and the information you provide, such as gender, age, Your skin type, Your skin concerns (such as sensitivity), and Your skin priorities, you will be provided with your skin results. Results may include information such as skin radiance, even tone, pore quality, pigmentation, firmness, fine lines, and wrinkles; a comparison to people within your age range and/or skin quality; and a suggested skincare routine.
Your Consent For Collection and Use of Your Personal Information
When You use MyRoutine AI, you specifically consent that:
- La Roche-Posay is collecting, capturing, possessing, storing, or obtaining the picture You provide, and data obtained or created from Your picture (including the automated recognition of various facial landmarks), that might qualify as biometric data, biometric information, or a biometric identifier under various laws.
- La Roche-Posay may share, disclose, or disseminate information about You with any other affiliated company or brand (including its parent and subsidiaries) as well as its service providers (such as the provider of cloud services used to provide You with the service).
When you consent to receive your results, You also agree to the storage or retention of personal information about you, including information derived from Your Image. Specifically, you consent that:
- La Roche-Posay will store personal information about You as described in our Privacy Policy , which will be retained subject to limitations in our Privacy Policy.
YOU UNDERSTAND THAT YOUR CONSENT TO THIS INFORMATION NOTICE IS A PREREQUISITE TO USE OF MYROUTINE AI.
La Roche-Posay’s MyRoutine AI Information Notice coexists with, supplements, and does not supplant, obviate, replace, or otherwise supersede or suspend any other policy applicable to Your use of La Roche-Posay’s website and MyRoutine AI, including the Terms of Use and Privacy Policy.
La Roche-Posay’s MyRoutine AI Information Notice is subject to periodic updating, including to the extent that La Roche-Posay begins collecting personal information for any other purposes not specified herein. La Roche-Posay reserves the right to amend this policy at any time, which amendments will further apply to Your use of MyRoutine AI subsequent to their enactment.
Data Retention
La Roche-Posay only briefly stores your selfie. Once the information is returned to You, Your selfie is deleted from the central cloud-based hub (generally within a matter of seconds of completion of the analysis).
The coordinates of facial landmarks, information you provide (gender, age, skin type, skin concerns, etc.), measurements made by the algorithm(s), calculations made from such measurements (i.e., skin concerns), the results from the analysis provided to You, and all recommendations provided to You are stored in the central cloud hub to help La Roche-Posay and its affiliates (including its parent and subsidiaries) improve its products and its users’ experiences. This data will be stored only as long as needed for La Roche-Posay and its affiliates’ (including its parent and subsidiaries) business purposes and in any event, no longer than 3 years after our last interaction with You.
Email Marketing
If You voluntarily provide La Roche-Posay with Your name and contact information (‘contact information’), or You sign up to receive promotional messages from La Roche-Posay, any information you provide while using MyRoutine AI (i.e., skin type, skin sensitivities, skin concerns, age), the results of the analysis (i.e., calculated age, calculated skin concerns), the skin report shown to You (i.e., skin analysis on key skin attributes), and all recommendations will be stored within Your profile at La Roche-Posay. If you provide La Roche-Posay with Your name and contact information, the information listed will be retained by La Roche-Posay in accordance with La Roche-Posay’s record retention and Privacy Policy and in accordance with applicable law. For residents of Illinois, we will only store information derived from the analysis of Your selfie (i.e., Your skin results) as long as needed by La Roche-Posay and in any event no longer than 3 years from the date of our last interaction with You.
Right to Delete
Depending on your location, You may have the right under the law of your state of residence to request deletion of, data about you at any time. In order to so indicate, You shall submit the request using the methods outlined in La Roche-Posay’s Privacy Policy.
If You request deletion of data about you, You understand and acknowledge that La Roche-Posay will keep a log of Your doing so, which log will include information such as Your name, date of request, manner of request, and date of fulfillment:
PLEASE NOTE that should You request deletion of data about You at a time when La Roche-Posay is compelled by law or order of court of competent jurisdiction to maintain such data, La Roche-Posay will not immediately comply with Your deletion request. We may also deny a deletion request where otherwise permitted to do so by applicable law.
Data Storage
La Roche-Posay uses a reasonable standard of care to store, transmit, and protect from disclosure any data used in MyRoutine AI consistent with the sensitivity of the data. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure.
Disclosure
La Roche-Posay may share, disclose, or disseminate personal information with any other affiliated company or brand. La Roche-Posay will also disclose personal information to La Roche-Posay service providers who help La Roche-Posay provide You with services. La Roche-Posay may disclose information in connection with the sale or purchase of our assets, or in connection with any bankruptcy or reorganization proceeding. La Roche-Posay may also disclose personal information to comply with federal or state law, local law, municipal ordinance, or court order, including in connection with a validly issued warrant or subpoena (or other legal process); to verify or enforce our Terms of Use or other applicable policies, to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our Sites, or the public.
For more information on La Roche-Posay disclosure practices, or for additional information about rights available to you, please visit our Privacy Policy.