PRIVACY POLICY

We’re based in CALIFORNIA in the UNITED STATES OF AMERICA. Many of our suppliers, affiliates and partners are based all over the world – as are many of our website visitors and valued customers. As a result, if you use https://www.talktohair.com  (the “Site”), it will involve transferring your personally identifiable information from your country to a country which might not have the same degree of protection in place. Please read the Privacy Policy carefully to understand how your personally identifiable- information is collected, used, and shared when you visit or make a purchase from our Site and also about how the law protects your rights.

 INTRODUCTION

Thank you for taking the time to review our privacy notice. You’re in the right place if you’re looking to find out what TALKTO HAIR does with your personal information when you visit or use our Site.

Talkto Hair respects your privacy and is committed to protecting your personal information. That’s why this Privacy Policy is issued based upon our good faith efforts to protect your privacy and in conformity with California Business and Professions Code, California Consumer Privacy Act (CCPA) and The EU General Data Protection Regulation (“GDPR”). For EU and California residents, special considerations may apply as set forth below.

INFORMATION WE COLLECT ABOUT YOU

When you visit the Site, we may collect, use, store and transfer different kinds of information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you (“Personal Information”).  

In particular, the Site collects and has collected the following categories of Personal Information from its visitors and consumers:

  • Personal Identification information includes your first name, last name, username or similar identifier, and title.
  • Profile Information includes your username and password, purchases or orders made by you, your interests, preferences, content of messages you send us, feedback, survey responses, product reviews and information related to return merchandise and warranties.
  • Contact Information includes billing address, delivery address, email address and telephone numbers.
  • Financial Information includes bank account and payment card details.
  • Transaction Information includes data about the products and services you purchase, including your product type, the serial or batch number located on the back of the product, your purchase date, payments to and from you and other details of products and services you have purchased from us.
  • Technical or Device Information includes internet protocol (IP) address, your login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites.
  • Usage Information includes information about how you use our websites, products and services.
  • Marketing and Communications Information includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

 HOW WE COLLECT YOUR DATA

You directly provide us with most of the data we collect. We collect data and process data when you:

  • Access this Site.
  • Register online or create an account on our Site.
  • Place an order for any of our products or services.
  • Voluntarily complete a customer survey or provide feedback on any of our message boards or via email.
  • Subscribe to our service or publications
  • Enter a competition, promotion or survey
  • Sign up for marketing information to be sent to you
  • Use or view our website via your browser’s cookies.

 We may also receive your data indirectly from the following sources:

  • Social networks when you reference our products or services.
  • Partners or affiliates with which we offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
  • Publicly-available sources such as data in the public domain.

We may also automatically collect Technical and Device Information about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Site might become inaccessible or might not function properly. For more information about the cookies we use, please see our Cookie Policy.

HOW WE USE YOUR INFORMATION

We only use your Personal Information to perform our contractual obligations with you and when the law permits. We collect your data so that we can:

  • enforce our rights and/or ensure your compliance with our Terms of Use;
  • fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations);
  • communicate with you regarding your purchase order or other similar activity on the Site
  • When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services;
  • use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns);
  • where it’s necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights don’t override those interests;

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

HOW WE SHARE YOUR INFORMATION

We only share your Personal Information to perform our contractual obligations with you and when the law permits. We collect your data so that we can:

  • disclose your Personal Information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, evidentiary privilege under California law, or legal process served on our Site;
  • disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep Personal Information confidential and not use it for any purpose except performing the contract or as required by law; although we may permit service providers to use aggregate or de-identified information which does not identify you. We share your Personal Information for business purposes with the following categories of third parties:
  1. Subsidiaries and affiliates.
  2. Data aggregators.
  3. Third parties with whom we partner to offer products and services to you.

Such business purposes may include identifying and serving advertisements, providing mailing services, providing financial services, web hosting, or providing analytic services. For example, we use Shopify to power our online store--you can read more about how Shopify uses your personally identifiable information here: https://www.shopify.com/legal/privacy.  We also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your personally identifiable information here:  https://www.google.com/intl/en/policies/privacy/.  You can also opt-out of Google Analytics here:  https://tools.google.com/dlpage/gaoptout;

We may also share your information with another business if we buy/sell any business or assets from/to them, or are otherwise combined with that business (including during any negotiations with them). If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this privacy notice.

Generally, we don’t rely on consent as a legal basis for processing your Personal Information (but where we do, you’ve got the right to withdraw consent at any time by contacting us.)

DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

Attention California consumers, in the preceding 12 months, we have disclosed the following categories of Personal Information for a business purpose to the parties identified above:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category E: Internet or other similar network activity.

Category F: Geolocation data.

Category G: Audio, electronic, visual, thermal, olfactory, or similar information.

Category H: Inferences about personal preferences and attributes drawn from profiling (e.g. via cookies)

SALES OF PERSONAL INFORMATION AND BEHAVIORAL ADVERTISING

Attention California consumers, in the preceding 12 months, we have not sold Personal Information.

However, as described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.  For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

FACEBOOK - https://www.facebook.com/settings/?tab=ads

GOOGLE - https://www.google.com/settings/ads/anonymous

BING-https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at:  http://optout.aboutads.info/.

California consumers-  You can also opt out by clicking this link:  DO NOT SELL MY PERSONAL INFORMATION

HOW WE STORE YOUR DATA

We take precautions to protect your information. When you submit sensitive information via the Site,  your Personal Information is protected both online and offline according to generally accepted industry standards. The computers/servers in which we store personally identifiable information are kept in a secure environment.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information.

No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. If you have any questions about security on our Site, you may contact us at star@talktohair.com.

HOW WE RETAIN YOUR DATA

When you create an account or place an order through the Site, we will maintain your Personal Information for our records unless and until you ask us to delete this information.

We’ll only keep your Personal Information 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 might keep your Personal Information for a longer period in the event of a complaint or if we reasonably believe there’s a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Please contact us at star@talktohair.com for details of retention periods for different aspects of your Personal Information.

MARKETING AND PROMOTIONAL OFFERS FROM US

We want you to be able to make choices about how we use your Personal Information, especially when it comes to marketing and advertising.

You’ll receive marketing communications from us if you’ve requested information from us (e.g. by signing up to our newsletter) or if you’ve purchased products from us and haven’t opted out of receiving marketing.

Either way, if at any time you change your mind and don’t want to receive marketing messages from us, you can tell us to stop by:

  • Unsubscribing (just click on the ‘unsubscribe’ link in any message we send you and follow the instructions – please note that it might take a short period of time to process your unsubscribe request); or
  • Sending an email to star@talktohair.com, with ‘Unsubscribe’ as the subject of the email
  • California consumers-  You can also opt out by clicking this link:  DO NOT SELL MY PERSONAL INFORMATION

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

YOUR RIGHTS

Under certain circumstances, you have the right to:

  • Request access to your Personal Information. This enables you to receive a copy of the Personal Information we hold, collect and use about you and to check that we’re lawfully processing it.
  • Request disclosure of information sold and disclosed of Personal Information collected, under CCPA. We are not obliged to honor a request to disclose information collected or sold where it would violate an evidentiary privilege under California law.
  • Opt out from any marketing, sales or other communication/data collection.
  • Nondiscrimination relating to exercise of CCPA rights for California consumers. We may not deny you goods or services; charge you different prices or rates for goods or services including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
  • Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we might need to verify the accuracy of the new information you provide to us.
  • Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there’s no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you’ve successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we’re required to erase your Personal Information to comply with local law. Note, however, that we might not always be able to comply with your request for erasure because of specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your Personal Information where we’re relying on our own legitimate interest (or that of a third party) and there’s something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You’ve also got the right to object where we’re processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios:
    • If you want us to establish the information’s accuracy.
    • Where our use of the information is unlawful but you don’t want us to erase it.
    • Where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You’ve objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your Personal Information to you or to a third party. We’ll provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal information. However, this won’t affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We’ll advise you if this is the case at the time you withdraw your consent.
  • Lodge a complaint with the relevant regulator if you feel that your Personal Information hasn’t been handled correctly, or you’re not happy with the way we’ve responded to anything you’ve asked us to do with your personal information.

If you are based in California you can contact the Attorney General’s Office at 1 (800) 952-5225 or here: https://www.oag.ca.gov/contact

If you’re based outside of the United States of America, you’ve got the right to complain to the relevant data protection authority in your country of residence. For EU citizens, HERE’S a list of EU data protection authorities with their contact details.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: star@talktohair.com

DATA TRANSFERS

Your Personal Information may be transferred to countries other than the country in which it was originally collected and your personal information may be processed and stored outside of your country of residence. Those countries may not have the same data protection laws as your country of residence and your personal information will be subject to applicable foreign laws. When we transfer your information to other countries, we will protect that information in the manner described in this Privacy Policy.

PROTECTING THE PRIVACY OF CHILDREN

This Site is not intended for children under 16 years of age in the United States. If you’re under the age of 16, please don’t give us your Personal Information. If we learn we have collected or received Personal Information from a child under 16, we will delete that information, unless we receive affirmative authorization (the “right to opt-in”) from the parent or guardian of a consumer who is between 13 and 16 years of age.

If you believe we might have any information from or about a child under 16, please contact us at star@talktohair.com.

PRIVACY POLICIES OF OTHER WEBSITES

This Site contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.   

CALIFORNIA PRIVACY RIGHTS-CCPA AND ‘SHINE THE LIGHT’ LAW

Under the CCPA regime, if you are a California resident, you have a right to request access to certain information about our collection and use of your Personal Information over the preceding 12 months, including specific pieces and categories of Personal Information; categories of sources for the Personal Information; and our business or commercial purpose for collection and use of your Personal Information; categories of third parties accessing your Personal Information; and any Personal Information disclosed and/or sold to third parties.

If you are exercising your right to access your Personal Information under CCPA, we will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is machine-readable, readily usable and portable.

As a California consumer, you have a right to request access to your Personal Information twice per year for free, under CCPA, unless the request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

As a California customer, you also have the right to receive, once per year, free of charge, 1) the identity of any third party company to which we have disclosed your personal information as defined by California’s “Shine the Light” law for that company’s own direct marketing purpose; and 2) a description of the categories of personal information disclosed. 

To request information under CCPA or Shine the Light law, please contact us at star@talktohair.com, the toll free number or the mail address set forth in the section entitled “Contact Us” below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are not required to respond to requests made by means other than through the provided email, phone number or mail address.

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. This privacy policy was last updated on may 13 2021.

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by:

Email at star@talktohair.com

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