Updated as of February 12, 2021
For clarity, "you" or "Users" of the Services may be "Clients", including anyone seeking hair, beauty, and other health and wellness services or "Professionals", including stylists; hair, beauty, health and wellness professionals; merchants; salons; and any employee of such merchants or salons (whether or not such employee independently registered for the Services).
Sources of Personal Data
We collect Personal Data about you from:
· when you provide such information directly to us, and
· when Personal Data about you is automatically collected in connection with your use of our Services.
[Our subsidiaries and affiliates (together, "Affiliates"), when they provide us with Personal Data about you.] Third Parties that share your Personal Data with us include:
· Service providers. For example, we may use analytics service providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
· Social networks connected to the services. If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your Account with us.
· [Advertising partners. We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements, or communications.]
Categories of Personal Data We Collect
- First name, last name, business name and information, mailing and/or physical business address, email address, telephone number, birth date, Social Security number, appointment information, location, IP address, physical characteristics or description, address, telephone number, education or business and professional licensing, employment, employment history, website search history, or information on a User’s interaction with a website, application or advertisement, physical location or movements, profile reflecting a person's preferences, characteristics.
The following sections provide additional information about how we collect your Personal Data.
Information Collected Automatically
We use the following types of Cookies:
· Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
· Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
· Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services' content for those who engage with our advertising.
· Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled "Information about Interest-Based Advertisements."
You can decide whether or not to accept Cookies through your internet browser's settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the "preferences" or "options" section of your browser's menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
Information about Interest-Based Advertisements:
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors, and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors ("Interest-Based Ads"). Information for Internet-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users' activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a "web beacon") from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research, and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
How We Use Your Personal Data
We process Personal Data to operate, improve, understand and personalize our Services. We use Personal Data for the following purposes:
· To meet or fulfill the reason you provided the information to us.
· To communicate with you about the Services, including Service announcements, updates, or offers.
· To provide support and assistance for the Services through email, SMS, or other forms of communication.
· To create and manage your Account or other user profiles.
· If applicable, publish information about users on the Website or Services.
· To personalize website content and communications based on your preferences, including targeted offers and ads served through the Services.
· To process Services or other transactions.
· To respond to user inquiries and fulfill user requests.
· To use the information Professionals submit about Clients or affiliated Professionals to send Clients and Professionals emails, SMS messages, or push notifications at such Client's or Professional's direction via the Services.
· To contact Clients to tell them about products and services that Professionals may offer and to further promote Professionals and the Services.
· To send Users marketing communications.
· To improve and develop the Services, including testing, research, analysis, and product development.
· To protect against or deter fraudulent, illegal, or harmful actions and maintain the safety, security, and integrity of our Services.
· To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Service.
· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
· In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy
· For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the "CCPA").
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
As noted in the list above, we may communicate with you if you've provided us the means to do so. For example, if you've given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our services. If you do not want to receive communications from us, please indicate your preference by emailing us at firstname.lastname@example.org.
How We Share Your Personal Data
Disclosures of Personal Data for a Business Purpose
We disclose your Personal Data to service providers and other parties for the following business purposes:
· Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
· Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
· Debugging to identify and repair errors that impair existing intended functionality.
· Short-term, transient use of Personal Data that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction.
· Performing services on our behalf, including maintaining or servicing accounts, providing customer service, fulfilling services and transactions, verifying customer information, processing payments, providing advertising or marketing services, or providing similar services on behalf of the business or service provider.
· Undertaking internal research for technological development and demonstration.
· Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture, was manufactured for us, or control.
We disclose your Personal Data to the following categories of service providers and other parties:
Service providers, including:
· Payment processors
· Ad networks
· Ad networks
· Hosting and other technology and communications providers
· Analytics providers
· Staff augmentation and contract personnel
Parties who acquire your Personal Data through an acquisition or other change of control.
· Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part)
Other parties at your direction.
· Other users (where you post information publicly or as otherwise necessary to a transaction initiated or authorized by you through the Services)
· Social media services (if you intentionally interact with them through your use of the Services)
· Third-party business partners who you access through the Services
· Other parties authorized by you
Over the past twelve months, we have disclosed the following categories of your Personal Data to service providers or other parties for the business purposes listed above:
· Personal identifiers.
· Customer records identified by state law.
· Internet or other similar network activity information.
· Geolocation data.
· Inferences drawn from other personal information.
· Age or date of birth.
Personal Data of Children
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data.
You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser, and signing off after you have finished accessing your account. Although we work to protect the privacy of your account and other Personal Data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any Personal Data you share with us, and we are not responsible for the theft, destruction, loss, or the intentional or inadvertent disclosure of your information or content.
You should never transmit personal or identifying information to other Users. If you suspect someone is trying to obtain your personal data by impersonating us or misleading you or other members of our community about such a person's relationship to us or to our Services, please contact us at email@example.com.
We retain Personal Data about you for as long as you have an open account with us or as otherwise permitted in the Terms of Service. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes, or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. We retain some Client information in a depersonalized or aggregated form but not in a way that would identify you personally. In the event that your Professional Subscription and/or Account is terminated or suspended, Masters reserves the right to promote you to Clients using information collected during your subscription term, including but not limited to, a general description of your business, customer reviews, or photographs, but excluding your contact information (such as phone number, address or email address).
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. We will provide you with the following information:
· The categories of Personal Data that we have collected about you.
· The categories of sources from which that Personal Data was collected.
· The business or commercial purpose for collecting or selling your Personal Data.
· The categories of third parties with whom we have shared your Personal Data.
· The specific pieces of Personal Data that we have collected about you.
If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient.
You have the right to request that we delete the Personal Data that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Exercising Your Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a "Valid Request." We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
· Emailing us at: firstname.lastname@example.org.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may have different tiers of Services as allowed by applicable data protection laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.