Privacy Policy & Notice

Last Updated: May 15, 2023

This Privacy Policy and Notice (we refer to it as our "Privacy Notice") describes how HC Salon Holdings, Inc. d/b/a Hair Cuttery Family of Brands, including Hair Cuttery®, Bubbles® Salons and cibu® ("HCFB," "we" or "us" ) collect, use, share, retain, and protect information about you when you (1) visit us at www.haircuttery.com, www.mycibu.com, www.bubblessalons.com, and www.haircutterycareers.com, or one of the pages thereon (the "Website"); (2) communicate with us or the Website via email and other electronic messages; (3) "login" and create an account on our Website; (4) use our other "Digital Platforms" of our mobile and desktop applications, as defined the Terms of Service for the HCFB Digital Platforms ; (5) agree to email and text messaging services from or with us; (6) provide information to us, face-to-face at our stores or via kiosks; or (7) otherwise interact with us online. We adopt this Privacy Notice to fulfill our service commitment to you and comply with legal obligations as we process personal information, described below.

This Privacy Notice does not apply to information collected or used by any third party, affiliate, or affiliate of a third party, including those that may link to or can be accessible via the Website. Please review their policies. HCFB is not responsible for the content or the privacy policies or practices of any third-parties, third-party websites, or third-party applications.

Before accessing, using, or interacting with the Website you should carefully review this Privacy Notice and the Terms of Service for the HCFB Digital Platforms, which are incorporated by reference and also govern use of the Website and Digital Platforms, and any other applicable terms, which are hereby incorporated by reference and can be viewed via links on the Website. We sometimes refer to these, collectively, as our "Agreement" with you. We may change our Privacy Notice, and any other part of our Agreement, from time to time and encourage you to review them whenever you interact with us.

User Consent: By choosing to interact with HCFB, including through our Website and by communicating with us via email, telephone or in person, you consent to the collection and use of information as described in this Privacy Notice and that you are over 13 years of age. If you are under the age of 13 or you do not consent to the collection, use and/or disclosure of your personal information as set forth in this Privacy Notice, please exit and do not use our Website or other applications or services.

No one under age 13 may provide any information to or on the Website or Digital Platforms. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information to us on or through our Website or Digital Platforms, make any purchases through the Digital Platforms, use any of the interactive or public comment features of our the Website or Digital Platforms or provide any information about yourself to us, including your name, address, telephone number, e-mail 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. If you believe we might have any information from or about a child under 13, please contact us via the methods set forth in the contact information section below.

It's important to use that you understand this Notice and the rest of our Agreement. If you have questions, feel free to reach out by using the Contact Us methods available on our websites and mobile app or by calling our Guest and People Care Center at 877-319-3919.

 

WHAT PERSONAL INFORMATION DOES HCFB COLLECT?

For purposes of this Notice, unless noted otherwise, when we use the term "personal information," we mean information that identifies, relates to, describes, references, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with a particular person or household ("personal information").

We may collect personal information that falls into the following categories:

  • Identifiers or Personal Information Categories: real name, postal address, Internet Protocol address, birthdate, telephone number, and email address;
  • Classification Characteristics: age, gender, gender identity or identification, sex, and marital status;
  • Commercial Information: products or services purchased, obtained or considered or your other purchasing or consuming histories;
  • Internet or Network Activity: browser history, device information and identification, operating platform, usage data, and cookie tracking;
  • Geolocation Data: physical location from your device, browser, or IP address, or IP address, which may include your precise geolocation depending on your device settings;
  • Professional, employment, and education information: we may ask for information about your education, employment, employment history, and other job application information in connection with your job inquiry or application for employment with us;
  • Inferences: we may also collect inferences drawn from our communications with you, information about your preferences that you provide to us (including with respect to your salon location, stylist, and hairstyle preferences), and the other information we collect, listed above.

 

HOW DOES HCFB COLLECT INFORMATION ABOUT ME?

We collect and store information that you give us directly. For example, when you:

  • Create an account: we may collect your name, address, email address, phone number, date of birth, and gender;
  • Apply on our Website for employment with HCFB: we may collect your name, state of residence, phone number, email address, whether you are a licensed cosmetologist, and the role for which you are applying. We may use a Third-Party service provider, Paradox, to assist with scheduling interviews, your application and other questions you may have. You can read Paradox’s privacy policy at www.paradox.ai/legal/privacy-policy;
  • Request customer support: we may collect your name, email address, phone number, and any other information you choose to provide to us regarding your request;
  • Email us and sign up for SMS messaging or other notifications: we may collect your name, email, mobile number, and address. We use a platform maintained by a Third-Party service provider, Braze, to process and store your information when you opt into SMS messaging. You can read Braze’s privacy policy at: www.braze.com/company/legal/privacy;
  • Purchase a product or schedule a service: we may collect and store the information about the product purchased or service scheduled and/or purchased, your purchasing, scheduling, and consuming histories, billing and shipping information, name, telephone number, and email. If you schedule a service or visit us at our salons or stores, a Third-Party service provider, Zenoti, collects and stores the information you provide on those visits. You can read Zenoti’s privacy policy at: www.zenoti.com/privacy-notice;
  • Participate in #MyHCStyle or #BubblesBesties: : if you choose to participate in #MyHCStyle, or #BubblesBesties, we may collect certain personal information in accordance with the terms of that program, such as your name, email address, screen name, photograph, or other image. You can read those terms at bubblessalons.com/bubblesbesties/terms-of-use.html and www.haircuttery.com/lookbook/terms-of-use;
  • Sweepstakes or contests: we may collect information, such as your name, email address, phone number, address, and other information in connection with your registration with a sweepstakes or contest that we may operate through the Digital Platforms, and in accordance with the terms of that specific sweepstakes or contest. Acceptance of a prize (except where prohibited by law) may also require you to allow us to post certain of that information on our Digital Platform, in the event that you win the contest or sweepstakes.
  • Use one of our Mobile Applications: we may collect information about you, such as your name, gender, birthday, email address, phone number, booking preferences, communication preferences, style and service preferences, scheduling history, location (including precise geolocation, depending on your device settings), and information about your device as well as your interactions with the app . You may also choose to provide information about an immediate family member if you have that person’s consent or, in the case of a minor child, you are that child’s parent or legal guardian, including that person’s name, birthdate, email address, phone number, and booking preferences.

We also receive and store certain types of information automatically when you interact with us online, with the Website, mobile apps, or any of our other Digital Platforms. For example, we use:

  • Cookies (small bits of information that are stored on your hard drive or in connection with your Internet browser) and other tracking technologies to gather information regarding your use and interaction with the Website, third party services, and certain other online activities (including sites you visit, your browser type, operating system, and interactions with our content and emails). This includes a device’s IP address device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website.
  • • Google Analytics to track the number of visitors to our Website, to provide us information regarding your browsing activities and interests, to process your device’s IP address (processed during your session and stored in a de-identified form), and to assist with debugging and quick logging. You can read Google Analytics privacy policy here: policies.google.com/technologies/partner-sites. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at tools.google.com/dlpage/gaoptout.
  • Unique Identifiers (such as a universally unique identifier or "UUID"), which we may store (including remotely) on your device persistently and may access, collect, or monitor in order to help you log in and navigate through the Digital Platforms.
  • Data and Mobile Analytics to collect information about your website usage, performance data, app errors, and debugging information from where the Website were downloaded.
  • Log File Information to learn your IP address, browser type, access times, domain names, operating system, the referring web page(s), pages visited, location, mobile carrier, device information (including IDs), search terms, and cookie information.

 

HCFB may also learn information indirectly about you, which you make publicly available, such as on a social network or shared with third parties. Please note, any content or information you share with or provide to third parties regarding HCFB, your communications with HCFB, or using or related to the Website may not be private or confidential and is not the responsibility of HCFB.

HOW DOES HCFB USE INFORMATION ABOUT ME?

HCFB may use and process information about you, including personal information, for one or more of the legitimate business purposes described in this Privacy Notice. For example, HCFB (and/or our Service Providers) may use information about you to:

  • Fulfill or meet the reason your information was collected or provided;
  • Deliver communications, information or services, and promotions;
  • Provide support to you and other users;
  • If you share or submit your photo to our Lookbook, your photo may be shared publicly on our Digital Platforms;
  • Present, optimize, and maintain the security of our Website and their contents;
  • Register, maintain, and provide notifications to you about your Website Account;
  • Detect and prevent fraud or other crimes;
  • Respond to law enforcement requests and as required by applicable law or court order;
  • Research, test, analyze, and develop our Website and services;
  • Allow you to participate in interactive features on our Website;
  • Personalize your Website experience and to deliver content, product and service offerings relevant to your interests, including targeted offers through our Website, third-party sites, and via email or text message (with your consent, where required by law).

 

DOES HCFB SHARE THE INFORMATION IT RECEIVES ABOUT ME?

HCFB does not and will not sell your personal information. We have not sold personal information in the past twelve (12) months. We may share information about you, including personal information, with third-party service providers with whom we have entered into contracts that require personal information be kept confidential and prohibit the retention, use, or disclosure of personal information for any purpose other than the services specified. We may also share information in accordance with the specific consents that we have received from you. HCFB does not share or disclose information for commercial purposes without your consent, except as described below:

  • Within the HCFB Family: We may share personal information internally within HCFB and with our subsidiaries and affiliates. HCFB’s personnel may have access to personal information as needed to provide and operate the Website in the normal course of business. This includes the following categories of personal information: identifiers or personal information categories, commercial information, internet or other network activity, geolocation data, and inferences drawn from personal information. The information you provide to HCFB when you opt into SMS messages regarding Hair Cuttery® products, services and deals is not shared with Bubbles® Salons or cibu®, for marketing their brand of products or services.
  • Third-Party Service Providers: We employ other companies and individuals to perform functions on our behalf, sending mail, analyzing data, providing marketing assessments, providing analytics information, processing certain payments, and providing data hosting (as specified herein). They have access to information needed to perform their functions, but not for other purposes. This includes the following categories of personal information: identifiers or personal information, classification characteristics, commercial information, internet or other network activity, geolocation data, and inferences drawn from personal information.
  • Business Transfers: If we purchase other businesses or their assets, sell our business assets, or are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information, including any category of personal data collected by HCFB, may be among assets sold or transferred and may be subsequently used by a third-party.
  • Lawful Requests and Safety: We release personal information when we believe it is appropriate to comply with the law, it is necessary to protect our interests, to prevent fraud or other illegal activity, and to protect the safety of any person. Nothing in this Privacy Notice is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.

 

HOW DOES HCFB SECURE INFORMATION ABOUT ME?

We realize that you trust us to protect your personal information. We take that trust seriously and maintain physical, electronic and procedural safeguards that are consistent with industry standards, to help protect the privacy, accuracy, and reliability of personal information and to protect it from loss, misuse, unauthorized access, disclosure, acquisition, exfiltration, alteration and destruction.

We also take commercially reasonable steps to ensure that our third-party service providers reasonably protect and secure your information. If HCFB becomes aware that a third-party service provider is using or disclosing information improperly, we will take necessary and immediate steps to end or correct such improper use or disclosure.

While we attempt to protect the information in our possession, and account for the protection of information provided to our third-party service providers through us, no security system is perfect and we cannot promise that information about you will remain secure in all circumstances. Please do your part to help us keep your information secure. You are responsible for maintaining the confidentiality of your password(s) and your Account(s), and for all activities that occur under your password or Account(s). HCFB specifically reserves the right to terminate your access to your Account(s) and any contract you have with HCFB related to the use of the Website in the event it learns or suspects you have disclosed your Account or password information to an unauthorized third party.

WHAT CHOICES DO I HAVE?

HCFB seeks to ensure all individuals are provided with the rights mandated by their governing jurisdiction. Not all of the rights discussed herein will apply to everyone and, depending upon your jurisdiction, may not apply to you.

If you are a resident of Virginia, Colorado, Connecticut, or Utah, you may have the right to request that HCFB:

  • Provide you access to recorded personal information that you have previously provided to us
  • Correct or amend inaccurate information we have about you
  • Delete the collected information assuming that request does not conflict with our legal obligations or other legitimate business purposes for maintaining information
  • Honor your request to opt-out of processing of personal data for purposes of targeted advertising, sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

Virginia, Colorado and Connecticut residents may also have the right to appeal our decision about your request

To exercise these rights or to appeal our decision about your request, as described above, please:

 

COMMUNICATIONS FROM HCFB

Users may opt-out of receiving certain communications from HCFB by following the unsubscribe process described in our communications, changing your account settings, or by contacting us by using the contact information provided above. Please note that such requests may take some time to fulfill and that certain Website-related communications, including but not limited to account verification, changes or updates to Website features, or technical and security notices are non-optional.

CHANGES TO OUR PRIVACY NOTICE

HCFB may modify this Privacy Notice from time to time. The most current version of this Privacy Notice will govern our use of your information and will be located at www.haircuttery.com/home/privacy-policy-legal.html, www.bubblessalons.com/privacy-terms/privacy-policy.html, and www.mycibu.com/pages/privacy-policy. You may contact us to obtain prior versions. We will notify you of material changes to this policy by posting a notice at the Website or by emailing you at an email address associated with your Website Account, if applicable, and provide an "at a glance" overview of any changes.

CONTACT FOR MORE INFORMATION

HC Salon Holdings, Inc., 1640 Boro Place, 4th Floor, McLean, Virginia 22102. Should you have any comments or questions about how we collect and use your personal information, communication can be directed to HCFB’s postal address, via email to privacy@haircuttery.com or by telephone at 877-319-3919.

In addition, you can call the Guest and People Care Center at (703) 269-5336 or contact us using the Contact Us methods available on our Digital Platforms.