Last Updated: January 9, 2020
PERSONAL INFORMATION WE COLLECT
- Order Information. When you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number.
- Pro Program Information. We also collect information from participants in our Pro Program. In addition to collecting [your name, billing and/or shipping address, email address, and phone number], we also collect photo identifications, school transcripts, professional license information, union cards and other relevant information depending on your membership level as further detailed at www.surrattbeauty.com/pages/pro-program (COMING SOON).
- Device Information. When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site.We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
Most web browsers are set up to accept cookies. You can, however, set your browser to refuse all cookies or to indicate when a cookie is being set. If you choose to decline cookies, some of the functionality of the Sites may be impaired.
HOW WE USE YOUR PERSONAL INFORMATION
We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:
- Communicate with you;
- Screen our orders for potential risk or fraud;
- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
We use the Pro Program Information that we collect to confirm your qualifications for participation in the program; to send you email and/or texts regarding the program, promotional and advertising material, product tips and tricks; to provide you with product discounts and new, pre-launch “gift” products; and to otherwise communicate with you regarding the program. [Any other specific uses?]
We 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).
SHARING YOUR PERSONAL INFORMATION
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal 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 Personal 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 will neither disclose nor sell any information about you to a party unaffiliated with us unless: (i) required to do so by law or legal process; (ii) required to do so by law enforcement authorities or other government officials; (iii) we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or injury to, or interference with, our rights or property or the rights or property of our users or others or in connection with an investigation of suspected or actual illegal activity; (iv) we reasonably believe that you have used information from the Sites in order to commit unlawful acts or acts that may endanger the health and/or safety of the public; and/or (v) we believe the law in good faith requires such disclosure.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident, you have the right to request information from us regarding the manner in which Surratt Beauty shares certain categories of personal information with third parties for their direct marketing purposes, in addition to the rights set forth above. Under California law, you have the right to send us a request at the designated address listed below to receive the following information:
1. The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
2. the names and addresses of the third parties that received the information; and
3. if the nature of the third party's business cannot be determined from their name, examples of the products or services marketed.
This information may be provided in a standardized format that is not specific to you. The designated email address for these requests is: email@example.com.
If you are a California resident, you may also request that we take the following actions:
- Disclose the categories of and sources from which we collect personal information;
- Disclose details about whether we sell personal information, and if applicable, what categories of personal information we sell and for what purposes;
- Provide you with personal information we have collected about you in a readily usable format;
- Delete personal information that we have collected about you; and
- Abstain from selling your personal information.
As described above, we may 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 using the links below:
- 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/.
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.
DATA RETENTION & SECURITY
When you place an order through the Site, we will maintain your Order Information and Pro Program Information for our records unless and until you ask us to delete this information.
Protecting your information is of primary concern to us. We store the information that we collect on secure servers and otherwise take reasonable precautions to protect your Personal Information. However, we cannot warrant and do not represent that our level of security meets or exceeds any specific standards. No Internet transmission is 100% secure or error-free, nor is stored data free from vulnerabilities. We neither guarantee the security of our websites, databases, or services, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the Internet. We are not responsible for the actions of third parties.
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 firstname.lastname@example.org or by mail using the details provided below:
[Re: Privacy Compliance]
Surratt Cosmetics LLC, 30 East 20th Street, Suite 6F, New York NY 10003, United States