Effective: February [_1_], 2022
1. Personal Information We Collect
1.1. Data provided directly by you
Contact and profile information. When you create an Account, complete your Account profile, sign up for a mailing list, or otherwise communicate or interact with us, we may collect information from you, such as your name, phone number, e-mail address, and physical address. We use this contact and profile information to: (i) create and personalize your Account; (ii) communicate with you directly about the Services as well as about any questions, issues or concerns you or other users may have, (iii) fulfill your order, and (iv) send you marketing communications in accordance with your preferences.
Payment information. When you submit an order you are required to provide payment information, such as your credit card, debit card or gift card details. For corporate Accounts that are used for business purposes, we may also have corporate credit card numbers or other payment account numbers. We use this payment information to fulfill your order, complete the transaction, and detect and prevent fraud.
Transaction information. When you submit an order, we collect information, including the items purchased, date and time of your transaction, and any special instructions. We use this transaction information to fulfill your order, update your rewards, detect and prevent fraud, personalize your experience, perform analytics/identify usage trends, and inform our advertising and marketing.
Communications, Participation and other content. We maintain all communications resulting from your interactions with us or with Beauty Professionals or Participating Hestla Salons by email, phone, mail or chat. We also record comments and opinions you express when responding to surveys, entering a sweepstakes or taking part in promotions we run. We use all of the foregoing communications to address your questions, issues and concerns and provide other related customer support services, for safety and security purposes, to improve our Services, and for analytics. We also maintain your ratings and reviews regarding Beauty Professionals or Participating Hestla Salons on the Platform, which we may post for the benefit of all of our users.
Other information you provide. With your permission, we may access your photos or contact list from your mobile device, Facebook Messenger account or email account to enable you to share content or promotions or invite your friends to connect with our Services, including through our friend referral program.
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 Services.
1.2. Personal Information Generated and/or Automatically Collected during your use of the Platform
Information about your device and its software. Information about your device and its software 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 may also work with third-party partners to employ technologies, including statistical modeling tools, that permit us to recognize and contact you across multiple devices. We use this device and software information to diagnose and fix technology problems, serve you personalized advertising, personalize your experience, perform analytics/identify usage trends, and improve our products and Services.
Information about the way you access and use our Services. Information about the way you access and use our Services includes the site from which you came and the site to which you are going when you leave. In addition, we track the pages you visit on the Platform, the links you click on the Platform, whether you open emails or click the links contained in emails that we send, other actions you take on the Services, and whether you access the Services from multiple devices. We may also use the information about the way you access and use our Services to determine products and services that may be of interest to you, to improve our products and Services, to evaluate the success of our advertising and marketing campaigns, and to send you marketing communications.
Analytics information. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends and the demographics of our users in order to improve our Services. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners.
We, or the third-party partners we use, may use the data collected automatically through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Platform; (b) provide custom, personalized content and information; (c) identify and contact you across multiple devices; (d) provide and monitor the effectiveness of our Services; (e) perform analytics and detect usage patterns on our Services; (f) diagnose or fix technology problems; (g) detect or prevent fraud or other harmful activities, and (h) otherwise plan for and enhance our Services and for other internal purposes.
1.3. Data from other sources
Information we receive from third-party sites you connect to our Services. We may receive personal information about you from third parties and combine that with information we collect through our Platform. For example, we may obtain information when you login through a third-party social network or authentication service, such as Facebook or Google. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, address book and contacts, or other information. Similarly, when you interact with us through a social media site or third-party service, such as when you like, follow or share Hestla content on Facebook, Twitter, or other sites, we may receive information that you permit the social network to share with third parties. The data we receive from these third-party sites is dependent upon that third party’s policies and your privacy settings on that third-party site.
Information we receive from affiliates or third parties. From time to time, we may receive information about you from Beauty Professionals or Participating Hestla Salons, in connection with our enterprise programs, from co-marketing partners, service providers, and from other third parties. For example, if your company, university or organization participates in one of our enterprise programs, we may receive your information from that participating organization for the purpose of setting up your Accounts or for billing purposes. We may receive additional information about you, such as fraud detection information, from third party partners and combine it with other information that we have about you. We use this information from affiliates or third parties to create your Accounts, to contact you, to send you advertising or promotional materials or to personalize our Services, to protect against bot attacks and account takeovers, and to better understand the demographics of our users.
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.
2. How We Use Your Personal Information
In addition to the uses described above, we may collect and use personal information to:
2.1. Provide, maintain, improve and develop the Platform and Services. We may use the personal information to provide, maintain, improve and develop the Platform and Services. For example, we:
- Enable you to create Accounts or otherwise access and use the Platform and Services (e.g., remember information so that you will not have to re-enter it during your visit or the next time you visit),
- Fulfill your requests and process payments (e.g., to allow you to order Services from Beauty Professionals or Participating Hestla Salons, or to provide you with information that you request),
- Provide custom, personalized content and information (e.g. “most popular near you” and “since you enjoy” features),
- Perform analytics, detect activity patterns on our Platform and Services, and otherwise research usage, and
- Test and develop new features and functionality and otherwise enhance the Platform and Services.
2.2. Maintain the safety, stability and security of our Platform and Services. We may use the personal information to maintain the safety and security of our Platform and Services. For example, we:
- Detect or prevent fraud, abuse or other harmful activities,
- Diagnose or fix technology problems,
- Conduct security investigations and risk assessments, and
- Improve and enforce our security measures.
2.3. Communications with you to provide support and other important messages. We may use personal information to communicate important messages to you and/or to provide you with support. For example, we might send you service-related emails or messages (e.g., user Account verification, changes or updates to features of the Platform or Services, technical and security notices) and other communications from or about Hestla.
2.4. Provide, personalize, measure and improve our advertising and marketing. We may use personal information to provide, personalize, measure and improve our advertising and marketing. For example, we:
- Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Hestla or its third-party partners,
- Inform you of products, programs, services, and promotions that we believe may be of interest to you, including, without limitation, through emails and push notifications,
- Permit you to refer us to your friends so that we may send them a promotional offer 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, email address, and other information you share with us. 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 use that information to send an email inviting the friend to visit the Platform and for any other purposes disclosed at the time of your participation in the program,
- Determine the effectiveness of our Services and our promotional campaigns, and
- Identify and contact you across multiple devices.
2.5. Legal and regulatory requirements and proceedings. We may use the personal information in connection with legal and regulatory proceedings and requirements. For example, we may need the personal information to enforce our corporate reporting obligations, or to comply with applicable laws.
3. Our Sharing and Disclosure of Personal Information
We disclose personal information to the following types of third parties:
3.1. Beauty Professional or Participating Hestla Salon Sharing. We disclose personal information to Beauty Professionals you order from or Participating Hestla Salons you receive services at and third parties engaged by those Beauty Professionals or Participating Hestla Salons (e.g. point of sale providers), as needed to fulfill your orders, including communicating with you about the status of your order or cancelled items. In some cases, you may also affirmatively opt in to share your information directly with a Beauty Professional or Participating Hestla Salon as will be disclosed on the Platform.
3.2. Other Third Parties necessary to complete your order or to enable your use of the Platform and Services. In addition to Beauty Professionals you order from or Participating Hestla Salons you receive services at, we disclose personal information to other third parties as needed to fulfill your orders, including, without limitation, beauty providers and payment processors.
3.3. Service providers and contractors. We disclose personal information to third parties that provide services for us or on our behalf, such as website hosting, data analysis, infrastructure provisioning, IT services, customer service, email delivery services, fraud detection, security monitoring, advertising and marketing, and other similar services.
3.5. 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.
3.6. 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. For example:
- Ad networks and advertising partners. We work with third-party Ad Networks and Advertising Partners to deliver advertising and personalized content to you on our Platform and Services, on other sites and services you may use, and across other devices you may use. These parties may collect information directly from your browser or device when you visit the Platform through cookies or other tracking technologies. This collected information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see our About Our Ads policy.
- Social networks. We disclose personal information, such as a unique identifier, hashed email address, or information automatically collected through tracking technologies, to social networks for the purpose of displaying personalized advertising and content on those social networks.
- Select Beauty Professionals or Participating Hestla Salons and brands. We disclose personal information to select Beauty Professionals or Participating Hestla Salons and brands from which you have placed orders through the Platform as well as their affiliates and third-party service providers. These Beauty Professionals or Participating Hestla Salons and brands, and their affiliates, may use your information as permitted by their own privacy policies, which could include sending you marketing communications and other promotional content.
3.8. Public. We make available through the Services certain features which may enable you to post information and materials, for example, ratings and reviews, photo uploads, and chat functionality. Please note that any information you provide in connection with such Services may be available to site visitors and to the general public. Please do not disclose your personal information in these public or interactive areas on the Services, and we urge you to exercise discretion and caution when deciding to disclose any other information and/or materials in these public or interactive areas on the Services.
3.9. 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.
3.11. Consent. We may disclose personal information about you to other third parties with your consent.
4. Control Over Your Personal Information
Profile Settings. You may update your profile information in the “Your Account” section of the Services.
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. For instance, you can withdraw permission for the app to access your location data through your device settings, though we may continue to approximate your location based on your IP address or through other means.
To learn more about how you may control your advertising choices, please see our About Our Ads policy.
5. How We Store and Protect Your Information
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 Service. 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.
6. Children’s Personal Information
Our websites and online Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. 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 email@example.com.
7. Third-Party Websites
8. Region Specific Disclosures
We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:
- California. If you are a resident of the State of California in the United States, please click here for additional California-specific privacy disclosures.
- Nevada. If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt-out of future sales of certain covered information that a website operator has collected or will collect. To submit such a request, please contact us at firstname.lastname@example.org with the subject line “Nevada opt-out.”
10. Contact Us
Alternatively, inquiries may be addressed to:
Attention: Privacy Team
2900 Government Way #261
Coeur D Alene, ID 83815
Please note that email communications will not necessarily be secure; accordingly, please do not include credit card information and/or other sensitive personal information in your email correspondence with us.
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