PRIVACY POLICY

Last modified: November 11, 2020

Introduction

HC Salon Holdings, Inc. d/b/a Hair Cuttery Family of Brands (“Company,” “we” or “us”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide to us or to our affiliates when you use the “Digital Platforms” (as defined below) owned by us as well as those associated with or utilized by the brands we manage which include: Hair Cuttery and Bubbles Salons (collectively “Our Brands”). This policy describes our practices for collecting, using, maintaining, protecting, and disclosing that information.

Digital Platforms include the following:

Our websites and those owned or operated by Our Brands.
Mobile and desktop applications offered by us or Our Brands.

Email and text messaging services between us or Our Brands and you.
Our advertising and applications on third-party websites and services, including our social media properties.
Information at collection points at retail stores operated by Our Brands (e.g. information you disclose face to face or through a kiosk to schedule a service at a salon, information you supply to access our wireless internet).

This policy does not apply to information collected by any third party other than Our Brands.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Digital Platforms. By accessing or using our Digital Platforms, you agree to this privacy policy. This policy may change from time to time (see Links

Our Digital Platforms may contain links non-affiliated websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those websites. We are not responsible for the information practices of such un-affiliated websites.

Changes to Our Privacy Policy. Your continued use of our Digital Platforms after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

Our Digital Platforms are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Digital Platforms. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information to us on or through any of our Digital Platforms, make any purchases through the Digital Platforms, use any of the interactive or public comment features of our Digital Platforms or provide any information about yourself to us, including your name, address, telephone number, e-mail address, or any screen name or user name you may use. If we learn 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 via the methods set forth in the contact information section below.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Digital Platforms, including information:

Employment information (applicable to potential employees and employees), including professional or employment-related information required to be collected during the hiring process as applicable (e.g., social security number, driver’s license number, passport number, address, email, your professional licenses;
By which you may be personally identified, such as name, postal address, e-mail address, telephone number, date of birth or any other identifier by which you may be contacted online or offline;
that is about you but individually does not identify you, such as your personal preferences for salon services or products, your age, gender, interests or your location when you access and use certain Digital Platforms (when you enable those features on your device) and information about the websites you visit; and/or
About your internet connection, the equipment you use to access our Digital Platforms and usage details.

We collect this information:

Directly from you when you provide it to us.
Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, pixel tags and other tracking technologies.
From other sources, for example, our business partners, service providers and social media platform operators.

Information You Provide to Us. The information we collect on or through our Digital Platforms may include:

Hiring and employment related decisions and compliance purposes.
Information that you provide by filling in forms on Digital Platforms. This includes information provided at the time of registering to use our Digital Platforms, subscribing to our services or our social media feeds, entering into promotions/sweepstakes/contests/rewards programs, posting material on our Digital Platforms, providing us with feedback, checking-in to an appointment, obtaining products or services through Digital Platforms at Our Brands’ retail outlets. We may also ask you for information when you report a problem with our Digital Platforms.
Records and copies of your correspondence (including e-mail addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes, such as for customer satisfaction and market research.
Details of transactions you carry out through our Digital Platforms and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Digital Platforms.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Digital Platforms, or transmitted to other users of the Digital Platforms or other parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Digital Platforms with whom your User Contributions may be shared with. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Digital Platforms, we may use automatic data collection technologies to collect certain information about your equipment, mobile device, browsing and use actions, and patterns, including:

Details of your visits to our Digital Platforms, including traffic data, location data, pages you view and links you access, logs, and other communication data and the resources that you access and use on the Digital Platforms.
Information about your computer, mobile device and internet connection, including your IP address, device identifiers, operating system, geolocation, and browser type.

We also may use these technologies to collect information about your online activities over time but we do not collect information across third-party websites or other online services (behavioral tracking).

We may maintain the information we automatically collect or associate it with other personal information we collect about you or receive from third parties. It helps us to improve our Digital Platforms to deliver a better and more personalized service, and to better market our services, including by enabling us to:

Estimate our audience size and usage patterns.

Store information about your preferences, allowing us to customize our Digital Platforms according to your individual interests.
Speed up your searches.
Recognize you when you return to our Digital Platforms.

Recommend retail locations that are near your location and to help us market our services (if you have permitted us to collect information about your device’s location).

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or mobile device. 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 Digital 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 Digital Platforms.
Flash Cookies. Certain features of our Digital Platforms may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Digital Platforms. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
Web Beacons. Pages of our the Digital Platforms may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). We and our service providers also use web beacons in HTML emails to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Digital Platforms are served by parties not affiliated with us, including advertisers, ad networks and servers, content providers, and application providers. These parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Digital 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 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. For information about how you can opt out of receiving targeted advertising from many providers, see the Choices About How We Use and Disclose Your Information section below.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present our Digital Platforms and its contents to you.
To provide you with information, products, or services that you request from us and to otherwise respond to your inquiries.
To fulfill any other purpose for which you provide it.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Digital Platforms or any products or services we offer or provide.
To allow you to participate in interactive features on our Digital Platforms.
To better understand how users access and use our Digital Platforms, both on an aggregated and individualized basis for product improvement, research, and analytics purposes. For example, we will evaluate which features of our Digital Platforms are more (or least) used by users, and we will use this information to improve our offerings.

In any other way we may describe when you provide the information.
For any other purpose with your consent.

To comply with legal obligations, as part of our general business operations, and for other business administration purposes.

Where necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or property or violations of our Terms of Use or this Policy.

To provide appointment confirmations, reminders and notes of thanks.

We may also use your information to contact you and serve advertisements to you about: 1) our own (and Our Brands’) goods and services; 2) our affiliates goods and services; and 3) about the goods and services of other entities that we think may be of interest to you.

Disclosure of Your Information

We may disclose aggregated and anonymized information about our users, and information that does not identify any individual, without restriction.

We may disclose personally identifiable information that we collect as described in this privacy policy:

To our subsidiaries and affiliates for their use subject to the terms of this privacy policy.
To contractors, service providers, and other third parties we use to support our business so that they can provide services to us and Our Brands.

If (i) we or our affiliates are, or may be, acquired by, merged with, or invested in by another company, or (ii) if any of our assets are, or may be, sold or transferred to another company, whether as part of a bankruptcy, restructuring, reorganization, or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and advisors, including attorneys and consultants.
To fulfill the purpose for which you provide it. For example, if you share or submit your photo to our Lookbook, you photo may be shared publicly on our Digital Platforms.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government, regulatory, or law enforcement request.
To enforce or apply our terms of use, any terms of sale and product return policies, and other agreements between you and us, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect our or Our Brands rights, property, or the safety our customers, employees, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following 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 Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions.. If you disable or refuse cookies, please note that some parts of the Digital Platforms may then be inaccessible or not function properly.

We also utilize Google Analytics evaluate usage of our Digital Platforms, including to help us improve our Digital Platforms’ performance and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Do Not Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed above.

Promotional Offers from the Company. If you do not wish to receive text communications or promotional emails from us or Our Brands you can opt out of receiving those communications by following the “unsubscribe” links provided in messages you receive. If no such links are provided you can opt out of receiving further messages by contacting us at via the methods provided in the contact information section below.

Accessing and Correcting Your Information

You may access personal information about you that we have collected through the Digital Platforms by sending a request using the contact information in the section below. You can also request that we correct any such information in the same manner. To verify that the request is authentic, we may require that such request be sent from the email address associated with your personal information or we may ask that you provide other information to help us verify your identity. While we will comply reasonably with your request, we may need to retain some of your information for our own record keeping or to fulfill a legal obligation. If you delete, or ask us to delete, certain information, you may not be able to continue to access certain portions of the Digital Platforms without entering additional information.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

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 Digital Platforms, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Digital Platforms like message boards or blogs. The information you share in public areas may be viewed by any user of the Digital Platforms.

Unfortunately, the transmission of information via the internet is not completely secure. Although we use commercially reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Digital 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 Digital Platforms.

Links

Our Digital Platforms may contain links non-affiliated websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those websites. We are not responsible for the information practices of such un-affiliated websites.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. 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 Digital Platforms and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

HC Salon Holdings, Inc.

8281 Greensboro Drive, Suite 320

McLean, Virginia 22102

Attn: Legal - Privacy

privacy@haircuttery.com

In addition, you can call the Guest and People Care Center at 877-319-3919 or contact us using the “Contact Us” methods available on our Digital Platforms.

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