Effective: February [__1_], 2022
- Personal information we collect
1.1 Data provided directly by you
Contact and Account Information. When you express interest in partnering with us, communicate or interact with us, or create an Account and complete your Account profile, we may collect information from you, such as your name, phone number, e-mail address, service region and city, physical address, vehicle and registration information, date of birth, social security number, driver’s license number, driver’s license photograph and/or other photographs, insurance information, bank and bank account information, including routing and account numbers, tax information and cosmetology, business or other license information. We may use the photographs you submit to verify your identity, including through the use of facial recognition technology. For more information, please see the section titled “Photographs and Facial Comparisons”.
Other information you provide. When you communicate or otherwise interact with us, you may also provide us other information about yourself (e.g. during Beauty Professional [ratings and review submissions, feedback, disputes, etc.).
We may also use aggregate personal information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes as long as the end-product does not uniquely identify you or any other user of the Hestla services.
1.2 Personal information generated and/or automatically collected during your use of the Platform
Transaction Information. We collect information about how you use the Platform specific to the orders that you accept, reject and cancel, including, without limitation, the rates of acceptance, rejection and cancellation, the total number of deliveries you make, the date and time of delivery acceptances, rejections and cancellations as well as the date and time of completions, time required to complete deliveries, route information, and payment associated to each order.
Information about your device and its software. We collect information about your device and its software which includes your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an Ad ID), and other similar information. We also may collect mobile sensor data (such as bearing or direction, speed, latitude and longitude, altitude/height, activity type, and acceleration or deceleration) to improve location accuracy and analyze usage patterns.
Analytics Information. We collect analytics information which includes information about the way you access and use the Platform, such as the pages you visit on the Platform, the links you click on the Platform, your login history, whether you open emails or click the links contained in emails that we send, and other actions you take on the Platform. We may collect analytics data or use third-party analytics tools such as Google Analytics to collect this data. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners.
Location Information. Each time you access or use the Beauty Professional App, we may collect the precise location of your device when the Beauty Professional App is running in the foreground or background. If you label certain locations, such as “home” and “work,” we receive that information, too. [Your location information is necessary for Hestla’s auto-dispatching technology to coordinate fulfillment of all orders placed across our network of Beauty Professionals. Orders are offered to you based on demand and strategic fulfillment algorithms. Beauty Professionals that are not within a reasonable distance from clients or designated Participating Hestla Salons may be considered unavailable to receive orders. We also use the location information to track the progress and completion of orders for Beauty Professional Services. We may also approximate your location from your IP address when you access or use the Platform.
We typically collect the foregoing information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, mobile SDKs, location-identifying technologies, and similar technology (collectively, “tracking technologies”), and we may use third party partners or services to assist with this effort. Information we collect automatically about you or your device may be combined with other personal information we collect directly.
1.3 Data from other sources
Affiliates and third-party services. From time to time, we may receive information about you from background check providers, co-marketing and other lead generation partners, service providers, and from other third parties. For example, we receive publicly available information about a Beauty Professional’s driving record or criminal history as well as cosmetology, business or other licensing information from our background check providers, and we use this information to evaluate an individual’s eligibility to be a Beauty Professional.
Clients, Participating HestlaTM Salons and other Sources. We may receive additional information about you from our clients and Participating Hestla Salons (e.g. ratings and/or reviews). Other users or public or third-party sources such as law enforcement, insurers and licensing agencies may provide us information about you, for example as part of an investigation into an incident or to provide you support.
We do not control, supervise or respond to how the third parties providing your information process your personal information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
- How Do We Use Your Personal Information
Provide, Maintain, Improve and Develop the HestlaTM Platform and Services. We may use your personal information to provide, maintain, improve and develop the Platform and Services, including:
- To determine your eligibility and process your registration, including verifying your information to ensure its accuracy and validity as well as to evaluate your prospective or continued engagement (e.g. to verify your compliance with applicable contractual requirements),
- To verify your identity by confirming that the Beauty Professional applicant matches the Beauty Professional documentation submitted,
- Enabling you to provide the Beauty Professional Services by indicating your availability, accepting or rejecting orders, viewing your transaction logs for fulfilled orders, and managing your payment preferences,
- Collecting, confirming and verifying information about Beauty Professional Services performed by you,
- To compensate you for the Beauty Professional Services performed, including, setting up direct deposit, calculating payments owed and issuing payments to you,
- Creating and personalizing content on the Platform and your Account. For example, in association with your ratings and reviews, we may display your name, “HestlaTM Beauty Professional since” date, total number of ratings and reviews, the date(s) of posting, and information regarding your delivery history,
- Performing analytics, detecting activity patterns on our Platform and Service, determining the effectiveness of our promotional campaigns, and otherwise researching usage. For example, we may use personal information to calculate the percentage of our users who have a particular telephone area code, and
- Testing and developing new features and functionality and otherwise enhancing the Platform and Beauty Professional Services.
Communications with you to provide support and to send you other important messages. We or our clients and Participating Hestla Salons and our respective third-party service providers may use your personal information for the following communication purposes:
- To process your registration, notify you regarding the status of your application, and/or onboard you to using the Platform,
- To schedule and otherwise facilitate order arrangement and fulfillment (e.g. notify you of client or Participating Hestla Salon locations or send you other information and/or reminders),
- To assist and/or intervene if there are safety and security concerns,
- To notify you about pricing or other updates that will affect your Beauty Professional Services, and
- To send you important information regarding the Platform, such as certain changes to our terms, conditions, policies and/or other administrative information.
Because this information may be material to your use of the Platform, you may not opt out of receiving such communications. Please note that standard voice, data and message rates will apply for all forms of communication. Please contact your mobile phone carrier for details.
Maintain the safety, stability and security of our Platform. We may use the personal information to maintain the safety and security of our Platform, including, to detect or prevent fraud, misrepresentation, abuse or other harmful activities, and/or diagnose or fix technology issues.
Provide, personalize, measure and improve our advertising and marketing. We may use personal information to provide, personalize, measure and improve our advertising and marketing, including to inform you of products, programs, services, and promotions that we believe may be of interest to you, to determine the effectiveness of our Platform and our promotional campaigns, to enhance our marketing activities, and to permit you to refer us to your friends so that we may send them promotional offers through the Platform. If you wish to use this feature, you may be required to provide us with, and we may use, your friend’s name and email address. By using this functionality, you affirm that you are entitled to use and provide us with your friend’s name and email address for this purpose. We will not use your friend’s personal information for any purpose other than to allow promotional offers to be sent and/or to troubleshoot any issues with respect such promotional offers, unless we disclose such other purpose to you at the time you provide your friend’s personal information to us.
For clarity, Hestla does not and will not use any information provided by you and/or generated by your use of the Platform and Beauty Professional App to supervise or control you in performing Beauty Professional Services arranged using the Platform or Beauty Professional App.
- Our Sharing and Disclosure of Personal Information
We disclose personal information to the following types of third parties:
Clients and Participating HestlaTM Salons. We share your personal information, including your location information and your contact information, with clients and Participating Hestla Salons from which/whom you have accepted an order(s) so that they can track the order(s) and/or communicate with you. [Although we help Beauty Professionals and clients and Participating Hestla Salons communicate with one another to arrange for order generation and/or fulfillment, we do not share your actual phone number with the client or Participating Hestla Salon ].
Service providers and contractors. We disclose your personal information to third-party service providers to provide certain services, such as new Beauty Professional onboarding, scheduling, communications, data analysis, infrastructure provisioning, IT services, customer service, email service providers, payment processors or payment card providers, training and educational software providers, identity verification, and other similar services.
Analytics providers. We share personal information with third-party analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our Platform and Services.
Advertising, Marketing and Promotions providers. We share personal information with third parties in connection with co-marketing activities, the development of customized and targeted marketing campaigns, to launch promotions and for other similar advertising efforts.
Business Transaction or Reorganization. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of all or a portion of company assets. We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
Consent. We may disclose personal information about you to other third parties with your consent.
- Photographs and Facial Comparisons
From time to time, we may require you to submit photographs of yourself to Hestla. In some cases, including for Beauty Professional applicant onboarding, we may share these photographs with our trusted third party identity verification vendor who may use (i) a combination of machine learning tools and optical scans to authenticate your identity documents as well as (ii) facial recognition technology to produce a unique biometric identifier based on facial geometry that can be used to compare your photograph(s) to other photographs you have previously submitted (e.g. driver’s license, etc.) to determine the likelihood that the images are a “match.”
- Purpose: We, through our third-party service provider, perform facial comparisons to verify your identity, authenticate your identity documents and to protect against fraud, misrepresentation and unauthorized use of the Platform (e.g. identity-borrowing).
- Data Retention and Destruction: Hestla does not collect or store the biometric identifiers derived from your driver’s license photos and other photos submitted. Rather, this data may be generated and maintained by our trusted third-party vendor to perform the identity verification service on our behalf in accordance with our contractual agreements. Hestla may receive and store the results of the identity document authentication as well as the verification analysis.
Neither Hestla nor our third-party vendor use, disclose or retain your biometric identifiers for any other commercial purpose. Also, facial recognition technology may not be available in all jurisdictions. In those circumstances, Hestla may still collect your photographs and perform manual facial comparison analysis.
- Tracking Technologies and interest-based advertising
We may engage in interest-based advertising and use third-party advertising companies to serve you targeted advertisements and/or content based on your browsing history. We may share, or we may permit third-party online advertising networks, social media companies and other third-party services, to collect information about your use of our Platform over time so that they may play or display ads on our services, on other devices you may use, and on other websites, apps or services, including on social media sites. These third parties may collect information such as click stream information, browser type, time and date you visited, mobile device identifiers, your use of third-party applications, and/or precise geolocation data and other information. This information is used to more effectively advertise to potential new Beauty Professionals, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
Cookies and Flash cookies. Most browsers allow you to adjust your browser settings to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.
Blocking or deleting cookies may negatively impact your experience using the Platform, as some features may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies, you may not be able to block non-cookie technologies or the changes to your settings may have no effect. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android).
Google Analytics. We use Google Analytics to recognize you and link the devices you use when you visit our Platform and Service on your browser or mobile device, login to your Account on the Platform, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Platform and to tailor our content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.
- Control over your Personal Information
Changing Personal Information. You may review, correct and/or update certain elements of your personal information by either notifying us in writing and/or adjusting your settings in the Platform (where possible).
Access to your Device Information and Push Notifications. You may control access to your device information or opt out of push notifications through your “Settings” app on your device. However, you may lose some features or functionality if you decide to withdraw permission for the Platform to access information.
How to control your communications preferences. You can stop receiving promotional email communications by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the services, technical and security notices). You may also unsubscribe from receiving certain order-related text (SMS) or multimedia (MMS) messages by replying “STOP” to the number sending the message. To re-enable texts, you can text START in response to an unsubscribe confirmation SMS.
- How We Store and Protect your information
Data storage and transfer. Your information collected through the Platform is stored and processed in the United States. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.
Keeping your information safe. We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Platform. However, no security system is impenetrable, and we cannot guarantee the security of our systems. Please recognize that protecting your personal information is also your responsibility. Accordingly, we strongly recommend that you change your passwords often, use a combination of letters and numbers, make sure you use a secure browser, and otherwise take precautions when communicating your personal information on the internet. If you know or have reason to believe that your Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Account, please contact us following the instructions in the Contact Us section below.
- Other Important Notices Regarding Our Privacy Practices.
Note Regarding the Use of the Platform by Children. Under no circumstances is the Platform directed to, or intended to, collect or solicit personal information from children under the age of 13. Such individuals are prohibited from using the Platform and should not provide personal information to us. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you have a basis for believing that we have any information from a child under 13, please contact us at firstname.lastname@example.org.
Region specific disclosures
- California Privacy Rights. If you are a user of the Platform and a California resident, California’s “Shine the Light” law (California Civil Code § 1798.83) permits you to request and obtain from us once a year, free of charge, information regarding our disclosure of your Personal Information (if any) to third parties for direct marketing purposes. If this law applies to you and you would like to make such a request, please submit your request in writing to the address provided below.
Attention: Privacy Team
2900 Government Way #261
Coeur D Alene, ID 83815
Please note that email communications will not necessarily be secure; accordingly, you should not include credit card information and/or other sensitive personal information in any email correspondence with us.