Safe Harbor Privacy Policy
SAFE HARBOR PRIVACY POLICY FOR CONSUMER DATA
Hairstory Studio, LLC (the “Company” and sometimes referred to herein as “we”, “our” and/or “us”) is committed to upholding the highest ethical standards in its business practices and strives to collect, use and disclose Personal Information (as such term is defined below) in a manner consistent with the laws of the countries in which it does business. This Safe Harbor Privacy Policy (the “Safe Harbor Privacy Policy”) sets forth the privacy principles that the Company follows with respect to personal consumer information transferred from the European Economic Area (the “EEA”) and from Switzerland to the United States.
SAFE HARBOR
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (collectively, the “Safe Harbor Principles”) to enable U.S. companies to satisfy European Union (the “EU”) law requiring that adequate protection be given to personal information transferred from the EU to the United States. The EEA has recognized the U.S. Safe Harbor Principals as providing such adequate data protection. Consistent with its commitment to protect personal privacy, the Company adheres to the Safe Harbor Principles.
SCOPE
This Safe Harbor Privacy Policy applies to all Personal Information received by the Company in any format (including electronic, paper or verbal) from consumers in the United States, within the EEA and from Switzerland.
DEFINITIONS
The following terms are used throughout this Safe Harbor Privacy Policy and are defined here for clarification:
“Agent” means any third party that collects or uses Personal Information under the instructions of, and solely for, the Company, or to which the Company discloses Personal Information for use on behalf of the Company.
“Company” means Hairstory Studio, LLC, and its successors, subsidiaries (if any), divisions (if any) and groups (if any) in the United States.
“Personal Information” means any information or set of information that identifies or is used by or on behalf of the Company to identify an individual. Personal Information does not include information that is encoded or anonymized or which is publicly available information that has not been combined with non-public personal information.
“Sensitive personal information” means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, or that concerns health or sex life. Information will be treated as sensitive personal information where it is received from a third party that treats and identifies it as sensitive.
PRIVACY PRINCIPLES
The privacy principles in this Safe Harbor Privacy Policy apply to the collection, use and disclosure of Personal Information by the Company and are based on the Safe Harbor Principles.
NOTICE
When the Company collects Personal Information directly from individuals within the EEA, it will inform them about the purposes for which it collects and uses Personal Information about them and the choices and means, if any, the Company offers individuals for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to the Company, or as soon as practicable thereafter, and in any event before the Company uses or discloses the information fora purpose other than that for which it was originally collected or discloses the information to a non-agent third party.
CHOICE
For Personal Information, the Company will offer individuals the opportunity to choose (opt-in) whether or not their Personal Information is: (a) to be disclosed to a non-agent third party; or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For Sensitive Personal Information, the Company will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
INFORMATION INTEGRITY
The Company will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. The Company will take reasonable steps to ensure that Personal Information is relevant to its intended use and is accurate, complete, and current. We will only collect and store Personal Information that is relevant to fulfill the purpose of the request, and we will retain such information no longer than appropriate to fulfill the purpose of the request.
TRANSFERS TO AGENTS
The Company will only transfer Personal Information to an Agent where the Agent has provided assurances to the Company that the Agent provides at least the same level of privacy protection as is required by this Safe Harbor Privacy Policy. Where we have knowledge that an Agent is using or sharing Personal Information in a way that is contrary to this Safe Harbor Privacy Policy, we will take reasonable steps to prevent or stop such use.
ONWARD TRANSFER
The Company will only transfer Personal Information to a non-agent third party where such transfer is consistent with the notice provided to the individuals who are the subject of the information and any consent that those individuals have given.
ACCESS AND CORRECTION
Upon request therefore, the Company will grant individuals reasonable access to the Personal Information that it holds about them. In addition, the Company will take reasonable steps to permit individuals to correct, amend or delete information that is demonstrated to be inaccurate or incomplete. These requests can be made by contacting our Customer Service department at [email protected] and/or 1 (800) 835-9074 .
SECURITY
The Company will take reasonable precautions to protect PersonalInformation in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
ENFORCEMENT
The Company will conduct compliance audits of its relevant privacy practices to verify adherence to this Safe Harbor Privacy Policy. Any employee that the Company determines intentionally violates this Safe Harbor Privacy Policy will be subject to disciplinary action up to and including termination of employment.
DISPUTE RESOLUTION
Any questions or concerns regarding the use or disclosure of Personal Information should be directed to the Company at the address set forth in the Contact Information portion of this Safe Harbor Privacy Policy. The Company will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Safe Harbor Privacy Policy. For complaints that cannot be resolved between the Company and the complainant, the Company has agreed to participate in the dispute resolution procedures of the American Arbitration Association pursuant to the Safe Harbor Principles.
LIMITATIONS ON APPLICATION OF PRINCIPLES
Adherence by the Company to these Safe Harbor Principles may be limited:(a)to the extentrequired or permitted by law or legal process, such as to respond to or investigate a legal or ethical obligation or request or pursuant to court orders, subpoenas, interrogatories or similar directive carrying the force of law; and (b) to the extent expressly permitted by an applicable law, rule or regulation.
INTERNET PRIVACY
The Company sees the Internet and the use of other technologies as valuable tools for communicating and interacting with consumers. The Company recognizes the importance of maintaining the privacy of information collected online and has created a specific Privacy Policy (the “Internet Privacy Policy”) governing the treatment of Personal Information collected through the web sites that it operates. With respect to Personal Information that is transferred from the EEA or Switzerland to the U.S., the Internet Privacy Policy is subordinate to this Safe Harbor Privacy Policy.
CONTACT INFORMATION
Questions or comments regarding this Safe Harbor Privacy Policy should be submitted to the Company as follows:
Hairstory Studio, LLC
Customer Service
ATTN: Safe Harbor Privacy Policy
114 Liberty Street, 10th Floor
New York, New York 10006
Phone: (212) 300-4382
Email: [email protected]
CHANGES TO THIS SAFE HARBOR PRIVACY POLICY
This Safe Harbor Privacy Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. When we do, we will also revise the “last updated date” at the bottom of this Safe Harbor Privacy Policy. A notice will be posted on the our web page (www.purelyperfectproducts.com) for 60 days whenever this Safe Harbor Privacy Policy is changed in a material way.