Privacy Policy

Effective as of May 25th, 2018

INTRODUCTION

Thank you for choosing Scruples!

Scruples Professional Salon Products, Inc. (“Scruples”, “Company”, “we”, “our” and “us”) is committed to giving you the best possible online experience. To do this, we need to understand how you interact with our website.

That said, we take your privacy seriously and we are committed to being transparent about the data we collect about you, how it is used and with whom it is shared. This privacy policy (“Privacy Policy”) applies when you use our Services (described below). We offer our users choices about the data we collect, use and share as described in this Privacy Policy and within the settings contained in our customer dashboard.

This Privacy Policy describes what information this Website gathers about you and how we use that information.

As you use our Services, we want you to be clear about how your personal information is used and shared, as well as the ways in which you can protect your privacy.

Our Privacy Policy outlines:

1. DATA WE COLLECT
2. HOW YOUR DATA IS USED
3. HOW YOUR DATA IS USED
4. YOUR RIGHTS, PREFERENCES AND CHOICES
5. HOW WE PROTECT YOUR DATA
6. OTHER WEBSITES; LINKS
7. CHILDREN
8. CHANGES TO THIS PRIVACY POLICY
9. SECURITY
10. YOUR CALIFORNIA RIGHT TO PRIVACY
11. HOW TO CONTACT US

Services and Scope. This Privacy Policy applies to information we collect:

• On the Scruples website, located at www.scrupleshaircare.com (“Website”).
• In email and other electronic messages between you and this Website.
• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy or any other website that is owned or operated by Scruples or any other linked pages, features, content, mobile applications, and any other communications or services we offer from time to time in connection with any of the foregoing (“Services”) but excluding services that state that they are offered under a different privacy policy.

As a user of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy (which includes other documents referenced in this Privacy Policy) and updates. Please ensure that you read this Privacy Policy before transacting business with us. If you do not read it, or you disagree with any aspect of it, you should not use our Services.

Changes. By using this Website, you consent to the terms of this Privacy Policy as well as the Website Terms of Use. Scruples may change this Privacy Policy from time to time. If you object to any changes, you may close your account and discontinue use of the applicable Services. Each time a user uses any Service, the current version of the Privacy Policy applies. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

Please check back periodically for up-to-date information about our privacy practices.

Amendments to this statement will be posted at this URL and will be effective when posted. Your continued use of this Website following the posting of any amendment, modification or change shall constitute your acceptance thereof.

DATA YOU PROVIDE TO US

When you create an account; place an order or make a return or exchange; inquire about our Services; request emails from us about our offerings; opt-in to marketing activities; receive a gift from someone else who purchases through our website; follow us or submit information, including photographs, via third-party social media platforms (e.g., Facebook, Instagram, Twitter, Google+, etc.); enter a contest or participate in a marketing survey; or submit other information to us directly or through third-party services, you are asked to provide personal information that uniquely identifies you.

We collect the following types of personal information: your contact information (such as name, postal or email address, or phone number), salon information, cosmetology license number, birthdate, name and email address of gift card recipients, username and password, payment information such as PayPal, credit or debit card details, shipping information (including the shipping address and phone number), purchase history, shopping preferences (such as an interest in a particular product category), information about your age, information you provide by interacting with us through social media, and photographs that you submit on our sites or through our social media channels.

You don’t have to provide any information that directly identifies you to browse our website. However, we will ask you to provide certain personal information as necessary to provide you with requested products and services, complete the relevant transaction, or, if you wish, to avail of special features or functions of our website.

Content Posted by You. We may provide you with the ability to rate or review products or services we sell, or otherwise post content on our website our through our social media channels. Any comments or reviews that you provide are accessible to all users of the relevant platform and may be visible to others or collected by third-parties, so you should use discretion when posting information and you should not post personal information. If you do post personal information, you do so at your own risk.

DATA WE AUTOMATICALLY GET FROM YOU

We and our affiliates, analytics or service providers, and select businesses with whom we have marketing relationships, use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the website, tracking users’ movements around the website, and to gather non-sensitive demographic information about our user base as a whole. We may receive reports based on the use of these technologies on an individual or aggregate basis. Further information is contained below.

Analytics & Log Files. As is true of most websites, we gather certain information automatically and store it in log files. When you visit our websites, we automatically collect the following types of information: information about the device you use to access the Internet (such as the internet protocol (IP) address, internet service provider (ISP) or mobile carrier, proxy server, device type, browser and add-ons, and operating system), referring/exit pages, date/time stamps, information on your shopping behavior on our website (e.g., page views, paths you take through our websites, etc.), general geographic location information (e.g., country or city) that shows where you are when browsing our websites, and search terms that you enter to reach our websites or enter on our websites to find products. We utilize analytics services and log files to help us track the efficacy of our websites, help us learn more about our customers’ and visitors’ shopping behavior, and for troubleshooting and maintenance purposes. We may collect and summarize customer and visitor information in a non-personal, aggregate format for statistical and research purposes.

Google Analytics.Our website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage.

Cookies, Web Beacons and Other Similar Technologies.We use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Services and devices. Cookies are an industry standard, they are small text files that our site may place on your computer as a tool to remember your preferences. You may refuse the use of cookies by selecting the appropriate settings on your browsers, however please note that if you do this you may not be able to use the full functionality of this website.

Targeted Advertising.Third-party advertising companies may serve ads on our behalf across the Internet. They may collect information about you through cookies and/or web beacons on our websites and other sites, and then display targeted ads on various sites that you visit. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out. Please note this does not opt you out of being served ads. You will continue to receive generic ads. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement, you should contact the responsible advertiser directly. To opt out of third-party advertising or analytics, please see the section entitled “Your Rights, Preferences and Choices” below.

Social Media Features.Some of our websites include social media features, such as the Facebook “Like” button and widgets, the “share this” widget, interactive mini-programs that run on our site, or similar mechanisms from Facebook, Twitter, Instagram, Pinterest, YouTube, Google +, etc. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third-party or hosted directly on our websites. Your interactions with these features are governed by the privacy statement of the company providing it.

2.1 HOW WE USE YOUR DATA

We use your data to provide, support, personalize and develop our Services. How we use your personal information will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the information that we have about you to provide and personalize, including with the help of automated systems and inferences we make, our Services (including ads) so that they can be more relevant and useful to you and others. When providing direct services, advertising or marketing, or performing security, administrative, or customer service activities, we may use the information we collect in the following manner, including without limitation, to:

Providing Direct Services

• Complete a sales transaction, including to process and track website orders;
• Provide products and services that you request;

Advertising and Marketing

• Send you email updates, newsletters, promotions, surveys, and direct mailings;
• Manage your participation in events and sweepstakes;
• Communicate with you about our products and services, and to customize our communications with you, including by identifying preferences you provide to us;
• Analyze your purchases and preferences to better understand your product and service needs and eligibility and to tailor our online content to you;
• Share your Wish List with those whose email addresses you provide for the sole purpose of completing your request;
• Publish customer testimonials or photos;
• Analyze our marketing strategies and trends regarding your use of our website or social media channels;
• Facilitate your acceptance of offers made by our third-party marketing partners;
• Improve the effectiveness of our marketing campaigns; and/or
• To send follow-up communications thanking your for your business or inquiring as to your satisfaction.

Administration

• Register and manage your account;
• Administer our loyalty program;
• Track the efficiency of our website and help us learn more about our visitors’ and customers’ shopping behavior; and/or
• Improve our website experience.

Security

• Protect against error, fraud, unauthorized transactions, claims and other liabilities;
• Manage exposure to risk from unauthorized users;
• Enforce the terms of use on our websites; and/or
• Comply with applicable legal mandates, our policies, or industry standards.

Customer Service Activities

• Provide customer service when you need help and/or to improve customer experiences;
• Provide status updates on your order;
• Provide information concerning product recalls or products you have purchased; and/or
• Enable you to communicate with us through social networks or other interactive media.

2.2 HOW WE SHARE YOUR DATA

We do not rent or sell personal information to others. We may share information we collect with our business partners, advertising companies, and other third parties for the purposes described in this Privacy Policy

Marketing Partners. If you accept an offer from any of our third-party marketing partners, we will share your contact and billing information with that specific third party, in accordance with the terms of the offer. If you have previously requested that your personal information not be shared with third parties, but then later consent by accepting a third-party marketing offer available through one of our websites, we will share your contact and billing information with that specific third-party, in accordance with the terms of the offer.

Some of these operations may result in personal information collected by Scruples being stored or processed outside of the US and, as a result, your personal information may be accessible to law enforcement and regulatory authorities in accordance with the law of these foreign jurisdictions.

Service Providers. We use third parties to manage one of more aspects of our business operations, including the processing or handling of personal information. We may share personal information with such third parties to perform services on our behalf such as fulfilling online orders, email distribution, processing non-cash payments, sending marketing communications, servicing products, maintenance of your account, conducting research surveys, verifying and validating information that you have provided to us, delivering products, third-party advertising, and providing customer support services. When we do use an outside company, we use contractual and other appropriate means to ensure that your personal information is used in a manner that is consistent with this Privacy Policy. We do not share email addresses with third parties for the purpose of sending their own emails to you. Third parties will only have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

Scruples Family. We may share personal information amongst our corporate parents, subsidiaries, affiliates or divisions for internal business purposes in accordance with this Privacy Policy. If we share your information within its corporate family, we will ensure that your information continues to be used only in accordance with this Privacy Policy, your expressed choices, and in accordance with local privacy laws.

Third Parties. This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage, even if you have accessed the websites or services of those companies through our website. Our Services may offer services or features that are not owned or controlled by us. When you access or use third party services, you agree to comply with any applicable terms or conditions thereof. Links to third-party websites are provided solely as a convenience to you. Once you leave our website, we neither control nor have responsibility for third-party sites, their content, or their privacy practices. We encourage you to read the terms and conditions and privacy policy of each third-party service that you access or utilize. Some of our pages utilize framing techniques to serve content from our partners while preserving the look and feel of our website. Please be aware that you are providing your personal information to these third parties and not to one of our websites.

Direct Marketing and Do Not Track Signals. We do not share personal data with third parties for their direct marketing purposes without your permission.

Security. In the event we become aware that the security of the sites has been compromised or users’ personal information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with data protection and law enforcement authorities.

Sale or Transfer of Business or Assets. Any information we have about you may be transferred or disclosed to a purchaser or prospective purchaser in the event of a sale, assignment, or other transfer of all or a portion of our business or assets. Should such a transfer occur, we will use reasonable efforts to ensure that the transferee uses your information in a manner that is consistent with this Privacy Policy.

Legal Disclosure. We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others. It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations; or (4) protect the security or integrity of our Service. We attempt to notify customers about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order, or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

Data Controller. Unless explicitly stated otherwise, Scruples is the controller of your personal data provided to, or collected by or for, or processed in connection with our Services.

You may be aware that a new European Union law, called the General Data Protection Regulation or “GDPR” gives certain rights to individuals in relation to their personal data. As available and except as limited under applicable law, the rights afforded to individuals are:

• Right of Access: the right to be informed of and request access to the personal data we process about you;
• Right to Rectification: the right to request that we amend or update your personal data where it is inaccurate or incomplete;
• Right to Erasure: the right to request that we delete your personal data;
• Right to Restrict: the right to request that we temporarily or permanently stop processing all or some of your personal data;
• Right to Object:
• The right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
• The right to object to your personal data being processed for direct marketing purposes;
• Right to Data Portability: the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
• Right not to be subject to Automated Decision-making: the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

3.1 Rights to access and control your personal information

We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile to advertising opt-outs and communication controls.

• If you have registered for an account, you can access, review and manage many changes yourself via the Customer Dashboard and/or Professional Profile. Within the Dashboard or Profile, you can do things like update your profile information and change your communication preferences.
• If you have not registered for an account, or the information you are seeking is not available within the customer Dashboard, you can contact us at info@scrupleshaircare.com, and/or at our address.
  Scruples 8231 214th Street West Lakeville, MN 55044-9009
• For further details, see section 3.2 below.

For personal information that we have about you, you can request the following:

Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).

Change or Correct Data:If you have created an account on our website, you can edit some of your personal data through the customer dashboard. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.

Object to, or Limit or Restrict, Use of Data:You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., your personal data is inaccurate or unlawfully held).

Right to Access and/or Take Your DataYou may contact Scruples to request a copy of your personal data and can ask for a copy of personal data be provided in machine readable form. You can also ask to review any of the information that we have retained, how we have used it, and to whom we have disclosed it at any time by contacting us.

Right to Lodge a ComplaintYou have the right to lodge a complaint with your local supervisory authority or the Data Protection Commission (DPC).

3.2 Opting out of communications

We offer you choices about how to manage how we communicate with you.

Email/Direct Mail.You may opt out of receiving marketing emails from us at any time by sending an email to info@scrupleshaircare.com or by clicking on the unsubscribe link in our emails. You will continue to receive service-related emails (e.g. order status). To opt out of direct mail, please send your request to info@scrupleshaircare.com and include your postal address in the body of the email.

Targeted Advertising.If you do not want information about your activity on our sites to be used for tailored advertising, please visit the page hosted by the Network Advertising Initiative and follow the instructions there.

Cookies.You may disable cookies in your Web browser, but doing so will impact the usability of the website.

Updating Your Profile.You may update or correct your personal information related to your account through your Dashboard or by contacting Customer Support at info@scrupleshaircare.com. If you wish to request deletion of your personal information, then please contact us at info@scrupleshaircare.com . We will respond to requests within a reasonable timeframe. We retain and use your information as necessary to comply with our legal obligations, contractual statute of limitations, resolution of disputes, and enforcement of our agreements. Please note that we may not be able to delete all of your data upon request depending on the reasons above and the nature of your interactions.

Contests. From time to time, we may provide you the opportunity to participate in contests, sweepstakes, surveys and/or other promotions on our website. If you participate, we will request certain personal information from you. Participation in these contests, sweepstakes, surveys and/or promotions is completely voluntary, and you therefore have a choice about whether or not to disclose this information. We may use a third-party service provider to conduct these surveys or contests; in those cases, that company will be prohibited from using our users’ personally identifiable information for any other purpose. We will not share the personal data you provide through a contest, sweepstakes, survey and/or promotion with other third parties unless we give you prior notice and choice.

Gift Card Recipients.Your gift card recipient may contact us at info@scrupleshaircare.com to request an update, correction or deletion of their personal information. Again, for various reasons stated above, we may not be able to delete information upon request.

3.3 Data retention and account closure

If you wish to close your account, we will keep some of your data even after you close your account. We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms and Conditions, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed, but will destroy your personal data when it is no longer needed for the foregoing purposes, or we remove your personal information to render it anonymous.

Security.We monitor for and try to prevent security breaches. We implement appropriate security safeguards designed to protect your data. For example, electronic records are stored in secure, limited-access servers; electronic data is stored behind secured encryption access; we use technological tools like firewalls and passwords; and we ensure our employees are trained on the importance of maintaining the security and confidentiality of personal information. We regularly monitor our systems for possible vulnerabilities and attacks, however, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, organizational, or managerial safeguards.

SSL Technology.Our website uses encryption technology, such as Secure Sockets Layer (“SSL”), to protect your personal information during data transport. SSL encrypts ordering information such as your name, address, and credit card number.

Lawful Bases for Processing. We will only collect and process personal data about you where we have a lawful bases to do so. Lawful bases include consent (where you have given it), contractual necessity (where processing is necessary for the performance of a contract with you (e.g., to deliver Services you have requested)), and legitimate interests. Where we process data based on consent, we will ask for your explicit affirmative consent. We will rely on legitimate interests as a basis for data processing only where the processing of your data is not overridden by your interests or fundamental rights and freedoms.

At any time, you can withdraw consent you have provided by managing your Dashboard or by contacting us as set forth below, but that will not affect the lawfulness of the processing of your personal data prior to such withdrawal. Where we rely on legitimate interests, you have the right to object.

We may display advertisements from third parties and other content that links to third-party websites. We cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving the Scruples Service and any personal data you provide will not be covered by this Policy. Please read their privacy policies to find out how they collect and process your personal data.

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe we might have any information from or about a child under 13, please contact us immediately.

We may occasionally make changes to this Policy.

When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Scruples Service or by sending you an email. We may notify you in advance.

Please, therefore, make sure you read any such notice carefully.

We urge you to protect your own privacy. We recommend that you do not share your Website password(s) with anyone or in any unsolicited phone call or e-mail.

While our Website strives to ensure the integrity and security of our network and systems, Scruples cannot guarantee that our security measures will prevent third-party hackers from illegally obtaining this information.

If you are a California resident, you have the right to request information from us once per calendar year regarding the customer information we share with third parties for the third parties direct marketing purposes. To request this information, please send an email to info@scrupleshaircare.com with ‘Request for California Privacy Information’ in the subject line and in the body of your message. We will provide the requested information to you via an email response.

If you are a minor under 18 and have a profile on a Scruples Website, you may ask us to remove reviews or other content that you posted on the Website by writing to us at info@scrupleshaircare.com and providing as much detail as possible (i.e. date and caption) as to the post(s) you want removed. We will begin to process your request within 30 days. Please note that processing your request does not ensure complete or comprehensive removal of content that you posted.

If you have questions about how we collect, store and use personal data, please contact us at the following:

Email:info@scrupleshaircare.com

Phone:281-872-8030

Mail:
Scruples
8231 214th Street West
Lakeville, MN 55044-9009

Please remember that email sent over the Internet is not secure. If you send an email directly to us from your own email account, the contents will not be encrypted. Do not send sensitive information (like a credit card number) to us via unencrypted email. We are not responsible for any transmission by you of any personal information over the Internet.