Privacy Policy

Welcome, and thank you for visiting our Platforms!

When This Policy Applies

At HairClub^® (“HairClub”, “we”, “us” or “our”), we respect your concerns about privacy and we take steps to protect it. This Privacy Policy (“Policy”) aims to help you understand what personal data we collect from you through our websites, mobile apps and in-center (“Platforms”) to better provide you our services and products. We are committed to ensuring that the information you provide to us is used in accordance to the terms of this Policy and applicable law. The Policy sets forth our practices for collecting, using, maintaining, protecting, and disclosing your information, including your Personal Information (as defined below)

When This Policy Applies

Personal Data We Collect

Cookie Policy

General Privacy Rights and Choices

Disclosure of Personal Information

Security

Children’s Privacy

State Privacy Rights

Retention & Deletion

Complaints

Changes

This Privacy Policy applies to all the services and products offered under the HairClub brand. The Policy governs Personal Information collected from you directly, indirectly, and or automatically in person at any one of our locations; through any feature in the Platforms (including chats and comments); or via email, text, telephone, teleconference; and via any other electronic means, tools or applications, including social media sites which reference this Privacy Policy. The Policy does not apply to services that have separate privacy policies that do not incorporate this Privacy Policy.

What Personal Information Do We Collect?

We collect several types of information from and about our customers, prospective customers, and users of our Platforms, including but not limited to, information which relates directly or indirectly to you (“Personal Information”). For instance: name, postal address, e-mail address, telephone number; and information which relates to your use of our services or facilities, such as your gender, ethnicity, internet connection, “IP” address, the equipment you use, and your website or app usage details over time. All the information we collect, may eventually be attached to your profile once you become a client and will be considered Personal Information. Information which is aggregated or de-identified and does not identify or relate to you is not Personal Information and is not subject to this Policy.

How and When Do We Collect Personal Information?

HairClub collects Personal Information from you in different ways or at different points in time, including but not limited to:

Directly from you:

When you provide us your Personal Information, in person, during a telephone call, via teleconference, or via the Platforms.

When you fill out any form whether in person or on our Platforms, including but not limited to, the forms to schedule an initial consultation, to request service and product information, to report a problem with our Platforms or services, to receive communications, to receive HairClub offers, to participate in a sweepstake, quiz, game, or survey (“Form”).

When you interact with our Platforms, including but not limited to, through an interactive feature such as an interactive quiz, and or a third party platform, by posting comments or reviews about us, or when you initiate a live chat with one of our representatives.

When you correspond with us by sending us an email, a letter, a message through social media, or through any other form of electronic communication.

Indirectly:

We may collect Personal Information from third parties with whom we have a relationship, including but not limited to our marketing partners, business affiliates, data brokers, and technology providers (such as internet service providers, operating systems, browsers, social media seek programs, etc.). Please know that we are not responsible for the accuracy of the Personal Information provided to us by third parties or how such third parties collect and use Personal Information. Keep in mind that when you use social media, Information you have shared may be public, and accessible publicly and indexable by search engines.

Automatically:

We collect Personal Information using automatic data collection technologies, which help us gather data about you such as demographic information, your online behavior, your use of our Platforms, and interaction with any other platform associated with us (also known as behavioral tracking). We collect data through first and third-party cookies (see below on our use of cookies), web beacons, embedded pixels, local data storage, and other tracking technologies, as well as details from your internet provider about your IP address, location, internet connection, the equipment you use to access our Platforms etc. The information we collect through these automatic data collection technologies is often associated with your account and is then considered Personal Information.

Why Do We Collect Information and How Do We Use It?

We use Personal Information we collect from our services for the following purposes:

Find out how to contact you and determine how you wish to be contacted, including via telephone call, text message, email, or physical correspondence

Deliver any information, offers, promotions, products, or services that you may have requested

Notify you of HairClub’ s latest offers and promotions

Manage our business relationship including reminding you of an appointment, sending you a billing statement, upholding our legal agreements, making material changes to this website or our services

Better tailor our offers to your specific needs

Develop new services

Combine anonymous information we have collected with your Personal Information to have a complete profile about you

Improve the content and administration of our Platforms and our social or networking applications and our marketing content

Ensure that our advertising partners will display HairClub offers which may interest you as you browse the internet

Give you important notices regarding any of the above

Fulfill any other purpose for which you consented, or which may have been described to you when you provided the Information

Comply with legal requirements

Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Please note; however, that without cookies you may not be able to use some or all of the features of our Platforms.

In conjunction with obtaining information through cookies, we may obtain additional details such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone in which your device is located. We may also obtain information such as the address of the web page that linked you to our site and the IP address of the device you use to connect to the Internet.

To control which web servers collect this information, we may place tags on our webpages called “web beacons.” These are computer instructions that link web pages to particular web servers and their cookies.

To manage our use of cookies, please visit our cookie management tool, available in the Cookies Settings link on our Platforms.

General Privacy Rights and Choices

If you are in the European Economic Area (EEA), Switzerland, the UK, Canada; or a resident of a US state with specific privacy laws (like California); please refer to the respective dedicated section labeled “State Privacy Rights”. Otherwise, at your request, and as required by applicable law, we will:

Inform you of what personal data we have about you that is under our control;

Amend or correct such personal data or any previous privacy preferences you selected, or direct you to applicable tools; and/or

Delete such personal data or direct you to applicable tools.

Opt-out of our use of Personal Information for certain purposes (e.g. marketing communications).

To exercise any of your rights as Personal Information controlled by us, please click here. Where legally permitted, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others.

How Do We Communicate with You?

At HairClub our goal is to ensure that the way we communicate with you reflects your preference. That is why we use reasonable efforts to use your Personal Information in the manner you designate in accordance with applicable law.

Please take a moment to review the You Have Options section, to learn about what types of communications you may receive from HairClub in addition to administrative communications necessary to manage our relationship with you (“Marketing Communications”). Keep in mind that you may revoke or modify your consent to receive other Marketing Communications at any time but note that it may take up to 10 business days for your request to be processed.

You Have Options

Throughout our Platforms, you may be asked to provide us with your Personal Information. Use those opportunities to determine how you wish to be reached by HairClub^®.

Electing to be contacted for Marketing Communications is not a condition for our services. We want to hear from you and want you to be happy when you hear from us. You may change your preferences at any time by communicating with us as stated in the “How to Contact Us” section of this Policy.

Do Not Track Signals.

Please note that we currently do not respond to Do Not Track (DNT) signals. To learn more about browser tracking signals and DNT please visit http://www.allaboutdnt.org.

Disclosure of Personal Information

We will not share, rent, or sell any Personal Information to third parties, except as disclosed in this Policy or as permitted by law.

Social Networking Sites and third-party platforms. From time to time, when you interact with third-party company sites or platforms, such as social networking sites, analytics service, or an advertising network partner, these third-party sites or platforms may require that you or HairClub share your Personal Information. If you agree to interacting with those sites or platforms, such as by clicking on an ad on Facebook, or by logging in to your Zoom account for a teleconference with a HairClub employee, for instance, it means that you are consenting to our sharing of your Personal Information with those sites, and acknowledge that we will do so. Please note that once we share or post your Personal Information with such company, your Personal Information becomes subject to the other company’s privacy practices and may become public depending on those practices. HairClub will have no way to control what such company does with your Personal Information after you have consented to our sharing of it.
Analytics services and Advertising Networks and or Providers. When you visit our Platforms, we may be sharing Personal Information with certain parties about your browsing or usage, pursuant to our agreements with them, to measure and target ads about products and services tailored to your interests. These third parties use cookies, web beacons, pixel tags and similar technologies to collect or receive information about your interaction with us on our websites and elsewhere on the internet (“Tracking Data”) and use such Tracking Data to display ads for HairClub and other companies when you visit this or other websites. To learn more about browser tracking signals please visit http://allaboutdnt.org.
Affiliates. HairClub shares your Information with its affiliates, subsidiaries, or parent companies from time to time to provide services to you or when our affiliates, subsidiaries or parent companies require that Information to provide services to us. In addition, HairClub may share Information with its affiliates to coordinate its activities and services and to understand and take advantage of market opportunities. If we disclose your Personal Information to our affiliates, we require our affiliates to maintain administrative, technical, and physical security measures to protect your Personal Information in accordance with this Privacy Policy.
Service Providers. HairClub may share your Personal Information on a need to know basis with trusted third-party service providers, such as data analytics and marketing companies, online e-commerce platforms like Shopify and Amazon where we may sell our products and services to you, credit card companies, mailing services, calling centers, or subcontracting customer service agencies, when it is necessary for those third parties to provide services to you personally, or on our behalf. In general, third-party service providers used by us will only collect, use and disclose your Personal Information to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. For those providers, we recommend that you read their privacy policies so you can understand the manner in which your Personal Information will be handled by those providers. Once you leave our Platforms or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy.

We do not share your Personal Information with third-parties for their direct marketing purposes.

Legal and Safety Obligations. Under certain circumstances, we may be bound to disclose Information if (i) required to do so by law, search warrant, subpoena, court order or other legal process, (ii) requested by law enforcement or other government authorities, or (iii) if we believe such action is necessary to protect and defend the rights, property or personal safety of our company and its Platforms, visitors to the HairClub website, and clients of our services, generally.

Change of Control or Other Business Transactions. We may disclose Personal Information about you to prospective acquirers, their representatives and other relevant participants in connection with any sale, merger, acquisition, restructuring, or change in control involving all or a portion of the HairClub trademark and affiliated business, including in connection with bankruptcy or similar proceedings or transactions of the owner of the HairClub mark.

Security

Please know we place great importance on the security of any Information collected from our clients and visitors. We have implemented technical and organizational measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, destruction, or disclosure. We also restrict access to Personal Information to our employees, contractors and agents who need to know that information in order to process it for us, and who are subject to contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

Children’s Privacy

Our Platforms are intended for adults over the age of 18. We do not direct our Platforms to minors, and we do not knowingly collect personal information from children under 13 years of age. If you are under 13, do not use or provide any information on our Platforms. If we learn we have collected or received personal information from a child under 13 years of age without verification of parental consent, we will delete that information.

If you believe we might have any information from or about a child under 13 years old without the appropriate parental consent, please contact us as directed in the “How to Contact Us” section of this Policy.

State Privacy Rights

Certain foreign jurisdictions (e.g. Canada or the UK) and US states provide their residents with specific rights regarding their Personal Information, including the “right to know” or access their information, the “right to delete”, and the “right to opt-out”.

Right to Know. You have the right to request that we disclose information about our collection and use of your personal information over the past 12 months, including, what categories of personal information we have collected about you; categories of sources from which the personal information is collected; categories of Personal Information that we sold or disclosed for a business purpose about you; categories of third-parties to whom the Personal Information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling Personal Information. Please note that much of the information you can make a request for is already contained in this Policy. Should you wish to exercise this right, please see the “How to Contact Us” section below which explains how to do so. We may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request.

We will provide access to your Personal Information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions may include, without limitation:

Information protected by attorney-client privilege.

Information that is part of a formal dispute resolution process.

Information that would reveal the Personal Information or confidential commercial information of another person or business.

Information that is prohibitively expensive to provide.

If we deny your request for access, we will provide you with a reason why your request was denied.

Right to Correct Information. Under some laws, you have the right correct or rectify incorrect Personal Information that we hold about you, subject to certain exceptions as required or permitted by applicable law.

You can submit your request through the link in the “How to Contact Us” section of this Policy. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you are concerned about our response or would like to correct the information provided, you may contact us through the means listed in the “How to Contact Us” section of this Policy.

Right to Delete. You have the right to request that we delete your Personal Information; however, this right is limited by several exceptions. Fundamentally, if we have a permissible need to retain Personal Information, we are not under an obligation to delete such information, even when requested. Generally, we retain Personal Information so we may complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; debug to identify and repair errors that impair existing intended functionality of our online properties; enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; comply with a legal obligation; or otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which your provided the information. As such, we generally do not accept requests to delete Personal Information. However, we will respond to requests to remove Personal Information from some of our systems as a part of a request to close or otherwise disable a membership account. If you would like to request deletion of Personal Information, please see the section below which explains how to do so. We may ask for some Personal Information to verify your identity and your rights to the data subject to your request.

Right to Opt-Out. We do not sell your Personal Information to third-parties as defined by California law. As such there is no need for you to opt-out of the sale of your Personal Information. However, we do share Personal Information with third-parties for marketing purposes and permit our marketing partners to collect data directly from you. You may choose to opt-out of the sharing of your Personal Information with third-parties for marketing purposes at any time by submitting a request as specified in the “How to Contact Us” Section below. Please note that this opt-out does not prohibit disclosure made for non-marketing purposes.

Designating an Authorized Agent. Some state law permits residents to designate an agent to manage their rights under applicable state law. If you would like to designate an agent to manage your privacy preferences, you may do so using the mechanisms noted below under “How to Contact Us”. We may ask for some Personal Information to verify your identity and your rights to the data subject to your request. We will also need sufficient Personal Information about your authorized agent to be able to identify them. As part of this process, you must have permission from your authorized agent to disclose their Personal Information to us for the purpose of acting as your agent. We may request that the designated agent provides us with your signed permission to act on your behalf.

Non-discrimination. We will not discriminate against you for exercising any of your privacy rights.

International Transfers

When you provide us with Personal Information to complete a transaction, including to obtain additional information or purchase a product from us in any of our Platforms, we understand that you consent to our collection, processing, and storage of such information. We may disclose Personal Information that we collect, or that you provide, as outlined in the Disclosure section above.

We are based in the United States and as such we may transfer your Personal Information to jurisdictions other than the jurisdiction in which the information was originally collected, and your information may be processed and stored outside of your jurisdiction of residence. Those jurisdictions may not have the same data protection laws as your jurisdiction of residence and your information may be subject to applicable foreign laws. If we transfer your information to other jurisdictions, we will protect that information in the manner described in this Policy.

You are welcome to contact us if you have questions regarding the collection, use, disclosure or storage of Personal Information by our service providers and affiliates outside Canada, and/or to obtain access to written information about our policies and practices with respect to service providers (including affiliates).

For questions about our privacy practices, please see the “How to Contact Us” section below.

Legal Basis for Processing Personal Data

We only use your information in a lawful, transparent, and fair manner. Depending on the specific Personal Information concerned and the factual context, we rely on the following legal bases as applicable in your jurisdiction:

As necessary to provide you with contracted services: We process your Personal Information on the basis of our contractual relationship in order to perform and manage our services to you pursuant to the transaction (i.e., providing you with our services, products, manage our relationship including billing, compliance with contractual obligations, and related administration). If we do not process your personal data for these purposes, we may not be able to provide you with all services and products;

Consistent with specific revocable consents: We rely on your prior consent to utilize cookies to engage advertising and analytics partners to deliver tailored advertising and analysis of our website usage. You have the right to withdraw your consent at any time by visiting our cookie management tool, available Cookies Settings;

As necessary to comply with our legal obligations: We process your Personal Information to comply with the legal obligations to which we are subject for the purposes of compliance with applicable laws, regulations, codes of practice, guidelines, or rules applicable to us, and for responses to requests from, and other communications with, competent public, governmental, judicial, or other regulatory authorities;

To protect your vital interests or those of others: We process certain personal data in order to protect vital interests for the purpose of detecting and preventing illicit activities that impact vital interests and public safety, including child sexual abuse material; and

As necessary for our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data: We process your personal data based on such legitimate interests to (i) enter and perform the contract with the account owner and/or reseller providing you with the Products (which includes billing, compliance with contractual obligations, and related administration and support); (ii) develop, test, and improve our Products and troubleshoot products and features; (iii) ensure authentication, integrity, security, and safety of accounts, activity, and Products, including detect and prevent malicious conduct and violations of our terms and policies, prevent or investigate bad or unsafe experiences, and address security threats; (iv) send marketing communications, advertising, and promotions related to the Products; and (v) meet our corporate and social responsibility commitments, protect our rights and property and the ones of our customers, resolve disputes, and enforce agreements.

Retaining Your Information

We pride ourselves on ensuring that your Personal Information is retained for the period we may need it for to carry out our services. All personal information collected has a defined retention period, which is in-line with our Document Retention Policy, unless a longer retention period is required by applicable law. If you would like to find out how long your information is being retained, please reach out to us using the “How to Contact Us” section above.

Right to Complaint

We take any complaints about our collection and use of personal information very seriously. If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance. You may contact us directly at the privacy email in the “How to Contact Us” section below.

You also have the right to lodge a complaint to a data protection authority. For more information, please contact your local data protection authority.

Links to Other Websites

From time to time, our Platforms may contain links to or require the use of other websites, applications, services, and or software, not belonging to or under our control. We explicitly disclaim responsibility for or liability for the privacy practices or the content of websites which do not belong to or are not under our control. Please be aware that once you link to or use a third-party website, application, service, and or software, you are subject to such third party’s terms of use, privacy policy, and information collection, use, reproduction, and sharing practices. We specifically disclaim liability for any claim arising out of your use of such third-party website, application, service, and or software, in conjunction with or independently from your use of any of our Platforms or services.

How to Contact Us

To exercise your rights, please click here. If you have any privacy-related questions or comments related to this Privacy Policy, please use the following options to reach us.

By Mail:

Attn: Privacy Policy

HairClub

1499 West Palmetto Park Road

Suite 300

Boca Raton, FL 33486

By Phone:

1 (800) 681-0241

By Email Privacy Policy & Data:

privacypolicy@hairclub.com

Reach out to Customer Service or if you wish to no longer receive information from HairClub:

‍customerservice@hairclub.com

We will strive to respond to a verified consumer request within 45 days. If we require more time, we will inform you of the reason and extension in writing.

Changes to Our Privacy Policy

We reserve the right to change this Privacy Policy from time to time and will notify users of our Platforms by posting such change on this Privacy Policy page. If we make material changes to how we treat your Personal Information, we will notify you through a notice on the website home page, or at our sole discretion via email to the last email address provided by you. You are solely responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting and reviewing this Privacy Policy to check for any changes. The date the Privacy Policy was last revised is identified at the top of this Privacy Policy page.

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