Updated: 10/11/2021
Table of Contents
- Important information and who we are
- The data we collect about you
- How is your personal data collected
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
- Contacting MyHair360.com
- Glossary
- California Supplemental Privacy Notice
1. Important information and who we are
Purpose of this privacy policy
This Privacy Policy gives you information about how MyHair360.com collects and processes your personal data when you use the MyHair360.com and MyHair360.com services, including any data you may provide through the MyHair360.com platform and on our websites. It also includes information about your rights, including your right to object to certain types of processing we carry out.
This privacy policy applies to all users of our apps, websites (including MyHair360.com which operates through the www.MyHair360.com website), features, or other services anywhere in the world, unless covered by a separate privacy policy, such as (“MyHair360.com Services”).
Controller/Processor
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. MyHair360.com and our customers who are Event hosts are independent controllers of certain types of your personal data, such as the information you provide when you create an account to attend an Event (like name and email) and information about the Events you attend (like Event name and date and time of Event). Event hosts are the controller, and MyHair360.com is the processor, of materials submitted by the Event host in the course of creating or during an Event, and includes any personal data included in such materials.
If you use MyHair360.com services, Event hosts are the controller and MyHair360.com is the processor.
Changes to our privacy policy and your duty to inform us of changes to your personal data
We keep our privacy policy under regular review and it may be updated periodically. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will notify you by posting an updated, date-stamped version of this privacy policy on our website. If we make changes that materially alter the privacy policy, we will provide notice to you in accordance with applicable law. Notice may be by posting a notice on our website, by email to you at the email address that you most recently provided to us, or by other means, consistent with applicable law. Accordingly, please keep your account information, including email address, updated.
Your access to and use of third-party websites or services accessible through the MyHair360.com Services
The MyHair360.com Services include links to third-party websites and applications as well as to integration and partner providers of multiple different types of services associated with a particular Event.
Third party web sites, applications, and integrations.
Clicking on links to third party websites, content, applications, or integrations may allow those third parties to collect or share data about you. We do not control those third-party websites or content and are not responsible for their privacy statements or the way in which they collect or use your data.
Where you access or use third party services or integrations provided by an Event organizer, advertiser, sponsor or any other party who participates in an Event, we encourage you to request details of and read the privacy policy of that party. We do not control those third parties and are not responsible for their privacy statements or the way in which they collect or use your data.
2. The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data which includes your image and first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. This may also include government issued ID which you provide to verify your identity or audio-visual content which you appear in as you contribute to or interact with an Event.
- Contact Data which includes your home address, email address and telephone number(s).
- Transaction Data which includes details about payments you have made and other details of products and services you have accessed or used through the MyHair360.com Services. We do not store card details on our server. Credit and debit card payments are processed by a third-party on their secure payments server and all card details are fully encrypted and stored by them.
- Technical Data which includes your internet protocol (IP) address, your login data, browser type and version, hardware information, time zone setting and location, browser plug-in types and versions, operating system and website, and other technology on the devices you use to access the MyHair360.com Services.
- Profile Data which includes your username and password, purchases or orders made by you, your interests, volunteer record, preferences, feedback and survey responses.
- Usage Data which includes information about how you use our Services, as well as third-party platforms which you have linked to your use of our Services. Usage data includes metadata which provides additional context about the way the Services are being used such as length of visit, page views, navigation paths, and page interaction information (such as scrolling, clicks, mouse-overs, and mouse tracking) as well as information about the timing, frequency and pattern of use.
- Marketing and Communications Data which includes your preferences in receiving marketing from us and our third-party partners and your communication preferences.
- User Generated Content which includes data you submit as part of an Event or as a result of your interactions with the MyHair360.com Services such as Event materials, videos, chats, and messaging.
If you fail to provide contractually required personal data
Certain information is contractually required to use our services. For example, to access MyHair360.com’s platform you need to provide your name and email address. If you fail to provide required information, you will not be able to access our Services or we will not be able to perform the agreement we have or are trying to enter into with you.
Children
We do not knowingly collect or process personal data from children, and no part of our Services is directed to them. A “child” is a person (a) under 18 years old (for residents outside of the EEA, except for the Republic of Korea); (b) under 16 years old or such age needed to consent to the processing of personal data in their country of residence (for residents of the EEA); or (c) under 14 years old (for residents of the Republic of Korea). If you are a parent or guardian and you learn that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from a child without verification of parental consent, we take steps to remove that information from our systems.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity Data, Contact Data and other information by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you: (a) create an account with us; (b) subscribe (or are subscribed) to our Services; (c) interact in an Event; (d) request marketing to be sent to you; (d) enter a promotion or survey; or (e) give us feedback or contact us.
- Automated technologies or interactions. As you interact with the MyHair360.com Services, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We also collect Usage Data via cookies, server logs and other similar technologies which track your interaction with the MyHair360.com Services.
- Third-Parties. Depending on your use of the MyHair360.com Services, we may collect data about you from third-party service providers which you have linked to your use of our Services (including social media account and single-sign-on services), your employer, your administrator, the host or organizer of an Event you register for or attend, publicly available sources, data enrichment vendors, payment and delivery service vendors, advertising networks, analytics providers (such as Google Analytics), and our business partners. The information which we receive from third parties depends on what policies that third party follows and our and your respective relationships with the third party.
4. How we use your personal data
We have set out below, in a table format, a description of how and why we use your personal data, the categories of data used for each purpose and which of the Legal Bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To register you as a user of MyHair360.com and Events | (a) Identity (b) Contact | To provide access to Myhair360.com or Events. Performance of a contract with you |
To process any paid entry to an Event: (a) Managing payments, fees and charges (b) Verifying your identity and details of your payment method or credit card account (c) Communicating with you, for example sending you confirmation of your attendance for an Event. | (a) Identity (b) Contact (c) Transaction (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests |
To manage our relationship with you which will include: (a) Providing access to Platform services (b) Notifying you about changes to our terms or privacy policy (c) Asking you to leave a review or take a survey (d) Investigating complaints | (A) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how users use the MyHair360.com Event Platform and associated products/services) |
To administer and protect our business and our services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, administering our CRM, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To enable you to partake in a competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how users use the MyHair360.com Event Platform and to develop and grow our business) |
To deliver relevant Platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how users use the MyHair360.com Event Platform and to grow our business and inform our marketing and growth strategy) |
To use data analytics to improve our Platform, products/services, marketing, user and Partner relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of users for certain Platform services and to keep our services and web site updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about Events or other services available through the MyHair360.com Event Platform that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to develop the products and services available through the MyHair360.com Event Platform) |
Cookies
We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve the MyHair360.com Services and your experience, see which areas and features of our Services are popular and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
Advertising and Analytics Services Provided by Others
We may allow others to serve advertisements on our behalf across the internet and to provide analytics services. These entities may use cookies, web beacons and other technologies to collect information about your use of the MyHair360.com Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by MyHair360.com and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the MyHair360.com Services and other websites and better understand your online activity.
5. Disclosures of your personal data
We will share your personal data with the following recipients to achieve the purposes set out in the table “Purposes for which we will use your personal data” above.
Service providers
- Service providers acting as processors who provide our IT and system administration services.
- Providers of our cloud services such as AWS and Google.
- Payment Processors – for the purposes of payment transaction management.
- Our third-party partners, integration providers, and affiliates whom you engage with through the use of the MyHair360.com Services in order to facilitate the provision of the MyHair360.com Services.
Other Third Parties
- Hosts or Event organizers whose Events you attend through your use of the MyHair360.com Services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Regulators and other public authorities including law enforcement agencies where required by law.
- In connection with, or during negotiations of, any merger, sale or transfer of company assets, financing or acquisition of all or a portion of our business. If a change happens to our business, we will notify you.
6. International transfers
We will transfer your personal data outside your country of residence, including the European Region, in our performance of the services. When we transfer personal data out of the EEA, we ensure an appropriate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we only transfer data to them under the scope of a Data Processing Agreement which incorporates Standard Contractual Clauses, or another legally applicable data transfer mechanism, which require them to provide similar protection to personal data shared between Europe and the US.
7. Data security
We have put in place commercially reasonable security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. That said, no method of electronic transmission or storage is 100% secure and we cannot guarantee absolute data security.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect to our relationship with you, or as required or permitted by applicable law.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and certain information to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there are valid grounds for doing so and subject to applicable law.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Right to data portability. You may have the right to receive certain of your information in a structured, commonly used and machine-readable format and to transmit such information to another controller.
- Object to processing of your personal data where we process your data based on legitimate interest. We will assess your objection and determine whether we have any compelling legitimate grounds or legal justification for continued processing.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us as set forth in the “Contacting MyHair360.com” section below.
10. Contacting MyHair360.com
If you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights, please contact us as follows:
- Full name and address of legal entity: MyHair360.com
- Email address: info@MyHair360.com
11. Glossary
Legal Basis means the reason why, under law, we are permitted to process your personal data.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data on the basis of legitimate interests for activities where our interests are overridden by the impact on you. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. In respect to MyHair360.com, that is the performance of our agreement with you to make the MyHair360.com Services available. We are not involved in the processing of your Personal Data during any engagement you enter into with our third-party partners or integration providers.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
12. California Supplemental Privacy Notice
We do not “sell” the personal information of our organizers or users of the MyHair360.com Services as the term “sale” or “sell” is defined in the California Consumer Protection Act (“CCPA”). That mean means we do not sell, rent, or otherwise disclose your personal information in exchange for money or something else of value.
In addition to the rights described in our Privacy Notice above, California law grants California residents’ certain rights as set forth below:
- Notice. You have a right to be provided with a notice at minimum of the categories of personal information collected and the purposes for which it is used at or before the points of collection.
- Right to non-discrimination. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA, such as by denying or providing a different level or quality of goods or services, or charging different prices or imposing penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.
Submitting Requests
Requests to exercise your rights may be submitted by emailing us at info@MyHair360.com Please be prepared to provide your first and last name and email address that matches information we currently have on file. Where we are unable to verify your identity based upon this information alone, we may require additional details. We will respond to verifiable requests received from California consumers as required by law.
California Shine the Light Law
Under California’s Shine the Light law, California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any, and as defined under the law) that we have shared with third parties during the preceding calendar year for their own direct marketing purposes. Such requests may be made once per calendar year by emailing us at info@MyHair360.com In your request, you must include the statement “Shine the Light Request,” provide your first and last name, email address and residential address, and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency.