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Privacy Policy

BRIOGEO PRIVACY NOTICE

We value our relationship with you and take your privacy seriously. Briogeo (“Briogeo” or the “Company”) is committed to maintaining the privacy and security of your personal information in compliance with all applicable laws. We collect and process your personal information fairly and lawfully and in order to carry out our lawful business activities.

The purpose of this Privacy Notice is to identify how we may process, collect, use, store, disclose, share your personal information that we collect from you in connection with your use of our website (www.briogeohair.com) and dependent pages (the “Site”), or your purchase or use of products, content or other services from us (collectively, our “Products and Services”). 

California residents may access the Notice of Collection of Personal Information and Privacy Policy with information and rights required by the California Consumer Privacy Act (CCPA) through the link here https://cppa.ca.gov/ or by scrolling down. Residents of the European Union may access the Notice of Collection of Personal Information and Privacy Policy with information and rights required by the General Data Protection Regulation through the link here https://gdpr-info.eu/ or by scrolling down. Residents of Virginia, Colorado, Utah and Connecticut may access the State Privacy Policy and Notice with information and rights required under those states’ respective laws as applicable to the individual consumer by scrolling down.

We may update this Privacy Notice at any time, by posting the amended version on this Site including the effective date of the updated version. By accessing the Site after we make such changes to this Privacy Notice, you are deemed to have accepted such changes.

The Information We Collect About You

What is personal information?

For purposes of this Privacy Notice, we refer to personal information according to the following definition: “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual or household. Personal information does not include publicly available information or information that is de-identified or aggregate consumer information.

We collect personal information from you both when you provide it voluntarily and also automatically when you use our Site. By accessing our website or social media pages, submitting personal information to us, or purchasing our Products or using our online Services, joining our rewards program, setting up an account, or signing up for our newsletter, you consent to the collection, use, sharing and disclosure of such information as set forth in this Privacy Notice, as it may be updated from time to time.

We collect personal information that you voluntarily provide to us when you: use our Site, communicate with us, make a purchase, use our Services, provide us information, engage or connect with us through one of our social media pages, update or add information to your account, chat with a customer support specialist, or when you otherwise correspond with us.

In addition, we also automatically collect personal information about you in connection with your usage of our Site, including from third party marketers and e-commerce platforms that monitor usage of our Site.

Types of Personal Information We Collect

We may collect and use the following types of personal information in connection with your use of our Products or Services:

  • Personal contact details, such as name, mailing addresses, telephone numbers, and personal email addresses

  • Social media account information, if you use the option to log in with social media we will receive the information in your public profile

  • Account preferences and history

  • Financial information, such as credit card or debit card numbers. All debit or credit card transactions are processed by our third-party payment vendors. We do not collect, store or maintain any credit card or debit card information on or through our website after the transaction is processed and verified. Instead, it is transiently collected, shared with and processed through these third-party payment vendors using their platforms. We do not disclose your credit or debit card information to any vendors, other than our third-party payment vendors.

  • Geolocation information – based on your IP address

  • Device/browser type or identification

  • Your IP address, your browsing history, and your page views and other similar information

We never request or require you to provide any sensitive categories of data, but through our customer services interactions, we know that sometimes customers and users choose on their own to voluntarily share sensitive personal information with us about their age, race, gender or ethnicity, or medical information. If you decide to disclose this information to us, we may maintain a copy of the communication or other information for the purposes for which you provided the information to us (e.g., to have an inquiry answered, resolve a complaint, make a refund).

Automated Collection of Personal Information

In addition to personal information you choose to provide us, we and our third-party service providers and advertisers may use a variety of technologies to automatically collect certain usage information whenever you visit or interact with the Site. This information may include information we automatically collect as you browse the Site, including your IP address, device type or client/user identifier, browser type/identifier, operating system, pages visited, and other similar information.

Cookies: Our Site use “cookies” and similar technologies. Cookies are small text files sent by your computer or device each time you visit our Site, which are unique to your browser or device. Cookies make web surfing and browsing easier for you by saving your preferences so that we can use these to improve your next visit to our Site or keep track of your shopping cart items. We use first party cookies and services provided by third parties using third party cookies or tracking technology to provide us with information concerning your website activity and to provide you with advertising. Third parties may use third party cookies to collect information when you visit their websites for their own business purposes. Cookies help us learn which areas of our Site are useful and which areas need improvement. We use information from cookies and tracking technologies (e.g., pixels, web beacons) in order to improve and customize your browsing experience, for analytics and metrics about your visits to our Site (e.g. the information concerning the length of your visit to our Site, where your visit originated from) and for marketing our products to you. Other cookies are necessary for the Site to function properly or enhance the Site’s performance and functionality. By using our Site, you consent to the use of all cookies and tracking technologies. You can choose whether to accept cookies by changing the settings on your browser. Please consult your Internet browser’s documentation for information on how to do this. However, if you choose not to accept essential or functional cookies, the Site may not function properly and some features may not work as they were intended. When we use cookies or other similar technologies, we may set the cookies ourselves or ask third parties to do so to help us. For example, our ecommerce and web hosting provider may collect information concerning your website usage through cookies.

Cookies we use may be either persistent or temporary (or session) cookies. A persistent cookie retains user preferences for a particular website allowing those preferences to be used in future browsing sessions and remains valid until its set expiration date (unless deleted by the user before the expiry date). A temporary cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

  • Tracking Technologies, such as Pixels, Beacons: We or third parties may use pixels or beacons on the Site to count how many users visit certain pages or content, for analytics and metrics about your visits to the Site, and to serve you advertising.

  • Third Party Technology: We may use this automated collection of personal information to improve our marketing programs and content, and to target advertisements to you. We do not control and are not responsible for third party tracking technologies that may be used on our Site. Such third parties may serve you content based on tracking you across different websites. You consent to potentially encountering third party tracking technologies when you use our Site.

  • Advertisers: We use Google AdSense Advertising on our website. Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy. We have implemented the following advertising in connection with our Site:

  • Google AdSense Advertising.

  • Search Advertising and Remarketing with Google Search/Google Display/DoubleClick/Youtube

  • BING Search Advertising and Remarketing

  • Facebook/Instagram Advertising/Remarketing

  • Klickly network retargeting

  • Outbrain/Taboola network advertising and retargeting

  • Klaviyo/Mailchimp Email Marketing

  • Tik Tok

  • Klaviyo

  • Amazon

  • Amazon “Buy with Prime”Amazon Buy with Prime. When purchasing Briogeo products on Briogeohair.com through Amazon Buy with Prime, you may, if you so elect, agree to receive recurring text messages for marketing or promotion purposes from Briogeo at the email and cell phone number provided when joining. You may opt out of these messages at any time by clicking “STOP” on the text message, clicking “UNSUBSCRIBE” on the email, or by contacting us via email at support@briogeohair.com. Standard message & data rates may apply. Consent to receive these messages is not required to obtain any Products or Services.

  • Global-E

How We May Use Information About You

We collect and use personal information for the legitimate business purposes of Briogeo. These purposes include to provide you with Products or Services, to fulfill the purpose for which you provided us with your personal information, to communicate with you, to perform on a contract between you and the Company, to market our products to you, to process payment and shipping and for account management, to improve the functionality and effectiveness of our websites, to protect the security of our website, to protect against fraud, and to comply with applicable law, rules or regulations.

Who We May Disclose Your Personal Information To

We do not sell your personal information to third parties.

In some instances we may retain other companies and individuals to perform functions on our behalf as service providers or contractors, including, but not limited to, web hosting platforms, e-commerce platforms, customer service providers, credit and debit card processing companies, chat providers and shippers. Such service providers may be provided with access to your personal information to perform the functions for which they have been retained. Briogeo requires its service providers, who provide services on our behalf (such as our e-commerce platform) to maintain the security of your personal information.

We may also disclose your personal information to third party advertisers and advertising networks for cross context behavioral advertising purposes.

We may disclose any information, including personal information, we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request, to protect ourselves from fraudulent or illegal activity, and to defend against legal claims.

How We Safeguard Your Personal Information

We are committed to maintaining the security of your personal information in compliance with all applicable laws and our policy. We take commercially reasonable steps to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

How Long We Store Your Personal Information

We do not retain your personal data for longer than is necessary to fulfill the business purposes for which the information is being collected or processed or in order to comply with applicable legal or regulatory requirements. Personal data will be maintained for at least their minimum time period required retention under Briogeo’s records retention schedules.

Your Options Regarding Your Personal Information

You have choices about how we use your personal information to communicate with you and send you marketing information. You can opt out from receiving future marketing communications from us at any time by:

  • Using the unsubscribe function in the email or marketing information you receive from us; or

  • Contacting us as set forth under “**How to contact us**” below.

In addition, you have choices available to you through the device or browser you use to access the Services regarding your cookies and other browser settings. For information about privacy settings on your browser, see, for example, Google Chrome. You may also change the settings on your mobile device, which lets you choose how and whether your location is shared with us. See, for example, Apple.

Our Policy On Children’s Information

Our Site is not intended for use by children under 13 years of age. No one under age 13 may provide any information to us through the Site. We do not knowingly collect or use personal information from children under 13. If you are under 13, do not access, use or provide any information on the Site or on or through any of its features. 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.

Links to Other Website and Services

The Site may have links to other websites that are not operated by us. We have no control over how these websites may collect your information and no liability for the practices, policies and security measures implemented on these websites. You should read the privacy notices on those other websites before you submit your information through them.

Do Not Track Requests

We respond to browser ‘Do Not Track’ requests. We do not lodge behavioral advertising cookies when a Do Not Track browser mechanism is in place.

We do not control and are not responsible for third party tracking technologies that may be used on our Site. Such third parties may serve you content based on tracking you across different websites. You consent to potentially encountering third party tracking technologies when you use our Site.

How to Contact Us

If you have any questions or concerns about our use of your personal information, please do not hesitate to contact us through any of the methods listed below. If you have a complaint or concern about how we are using your personal information, then we will work to address such concern(s). 

Mail:

Briogeo

135 MADISON AVE, 5TH FLOOR, NY, NY 10016 

Email: support@briogeohair.com

Effective Date: May 25, 2018

Last Updated: December 4, 2023

  1. BRIOGEO NOTICE OF COLLECTION OF PERSONAL INFORMATION AND PRIVACY POLICY UNDER THE CALIFORNIA PRIVACY RIGHTS ACT (CPRA)

This Notice of Collection Of Personal Information and Privacy Policy (“CPRA Privacy Notice”) applies to the collection of personal information from California residents on and after January 1, 2023. This CPRA Privacy Notice supplements our “Privacy Notice” above to provide California residents with information and rights required by the California Privacy Rights Act (“CPRA”). The Privacy Notice applies only to individuals residing in the State of California who are considered “consumers” under the CPRA and from whom we collect “personal information” as described in the CPRA.

This CPRA Privacy Notice describes the types and categories of personal information we collect, the business purposes for which we process, collect, use, store, disclose and share your personal information, with whom we share it, and your rights in personal information under the CPRA. We share your personal information with third party advertisers for cross-context behavioral advertising within the meaning of the CPRA (i.e., targeting of advertising based on personal information obtained across businesses, websites, applications or services, other than the Company’s website or services). We do not sell your personal information.

For purposes of this CPRA Privacy Notice, we refer to personal information according to the following definition given in the CPRA: “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available information, information that is de-identified or aggregate consumer information, or information or rights that are outside the scope of the CPRA.

By accessing our website or social media pages, submitting personal information to us, or purchasing our products or using our online services, you consent to the collection, use, sharing and disclosure of such information as set forth in this CCPA Privacy Notice, as it may be updated from time to time. To opt out of sharing of your personal information with third parties, you may access our “Do Not Sell or Share My Personal Information” link. https://www.briogeohair.com/pages/do-not-sell

What categories of personal information do we collect about you?

  1. We may collect personal information from you in various ways including:

    1. ● when you provide us with information (e.g., through your communications with us by email, text, or telephone, via chat or through our Site and our Join Our Rewards program, Sign Up/Set An Account or Sign Up for our newsletter, or on our social media pages);

    2. ● when you communicate with us concerning our Products and Services;

    3. ● purchase our Products and Services; and

    4. ● through automated means when you use our website including by use of “cookies,” pixels, web beacons and other similar tracking technologies.

We collect the following categories of personal information. Theis table also sets out personal information we have collected over the last twelve (12) months:

Categories

Examples

Retention Period

Share with Third Parties

A. Identifiers

This information may include your name and contact details (including mailing and billing addresses, telephone numbers, email addresses, IP address, browser or device identifier, and other identifying information you provide to us). For example, we may collect your name and email address when you join our mailing list to receive information on our Products or Services, to receive discounts, or establish an account.

Length of Customer relationship, plus six [6] years. 

Yes

B. Customer Information under California Civil Code §1798.80I

This information comprises any information that identifies, relates to, describes or is reasonably capable of being associated with you or your household in our records. Examples include your orders and payment related information that we use to charge for our Products or Services, including debit or credit card numbers. All debit or credit card transactions are securely processed by our debit or credit card processing payment vendors. We do not collect, store or maintain any credit card or debit card information on or through our website after the transaction is processed and verified. Instead, it is transiently collected, disclosed to and processed through these payment vendors using their platforms. Your credit or debit card information will be stored with our payment vendors if you elect certain Products or Services so that we may periodically charge your card according to the Products or Services you elected. We do not disclose your credit or debit card information with any vendors, other than our payment vendors. Some personal information in this category may overlap with other categories.

Length of Customer relationship, plus six [6] years.

Yes

C. Characteristics of protected classifications under California or federal law. 

This includes demographic information, such as age, race, gender or ethnicity, or medical information related to our products, that you may voluntarily provide to us.

Length of Customer relationship, plus six [6] years.

No

D. Commercial Information

This category includes information concerning the Products or Services you purchased and your purchasing history and tendencies.

Length of Customer relationship, plus six [6] years.

Yes

E. Internet and other electronic history

This category comprises electronic information concerning your use of the website (www.briogeohair.com) and dependent pages (the “Site”). This information may include information we automatically collect as you browse the Site, including your IP address, device type or client/user identifier, browser type/identifier, operating system, pages visited, heatmaps of your web session and other similar information. We may use services provided by third parties using third party cookies or tracking technology to provide us with information concerning your website activity and market products to you. We may collect information concerning your website usage through cookies and other tracking technologies. 

Generally, for as long as one [1] year

Yes

F. Geolocation data. 

We may determine your approximate geographic location through your IP address in order to market our products at physical locations, such as retailers, that are nearby to you. Geolocation information is provided to us for use for marketing purposes based on third party marketers and e-commerce platforms that monitor usage of our Site. If you do not want us to collect geolocation data, you may change the settings on your mobile device, which lets you choose how and whether your location is shared with us.

Generally, for as long as one [1] year

Yes

G. Inferences drawn from information you provide to create a personal profile concerning your consumer preferences, characteristics, predispositions, behavior, and attitudes

We may accumulate the information you provide to develop a consumer profile concerning your behavior and interests, including for our marketing and advertising purposes, and to improve our Products and Services.

Length of Customer relationship, plus six [6] years.

Yes

We do not collect sensitive personal information for purposes of inferring characteristics.

We retain personal information for as long as needed to fulfill the purposes for which it was collected subject to the retention periods above. Your personal information may be retained longer if required or permitted by applicable law.

Our Business Reasons For Collecting And Using Your Personal Information

We collect and use personal information for the legitimate business purposes of Briogeo. These purposes include to provide you with Products and Services, to fulfill the purpose for which you provided us with your personal information, to communicate with you, to perform on a contract between you and the Company, to market and advertise our products to you, to process payment and shipping and for account management, to improve the functionality and effectiveness of our websites, to protect the security of our website, to protect against fraud, and to comply with applicable law, rules or regulations.

What are our categories of sources of personal information

The Company collects personal information from the following categories of sources:

  1. ● directly from you;

  2. ● service providers providing services on our behalf. We require our service providers who we provide your personal information to in order to provide services to maintain the privacy and security of your personal information; and

  3. ● third parties, including advertisers.

Who we disclose or share your personal information with

We do not sell your personal information to third parties.

We do share your personal information with third party advertising vendors for cross-contextual behavioral advertising purposes. We use information from cookies and tracking technologies (e.g., pixels, web beacons) in order to improve and customize your browsing experience, for analytics and metrics about your visits to our Site (e.g. the information concerning the length of your visit to our Site, where your visit originated from) and for marketing our Products and Services to you. Other cookies are necessary for the Site to function properly or enhance the Site’s performance and functionality. 

Third party advertising vendors use cookies and other technologies to serve ads based on your visits to the Site. Those third party cookies enable those advertisers to serve ads to our users based on previous visits to our Site and other sites on the Internet. These technologies are able to link your other Internet activity with our Site for purposes of providing you with advertising that you may be interested in. 

If you do not want your personal information shared for advertising purposes, including through third party cookies placed in your browser or other tracking technologies, please see our “Do Not Sell or Share My Personal Informationhttps://www.briogeohair.com/pages/do-not-sell.  

You may also be able permit or limit certain types of cookies by changing the settings on your browser or going to our Privacy Preferences. Please consult your Internet browser’s documentation for information on how to do this. However, if you decide not to accept essential or functional cookies through your browser settings, the Site may not function properly and some features may not work as they were intended.

In some instances we may retain other companies and individuals to perform functions on our behalf as service providers or contractors, including, but not limited to, web hosting platforms, e-commerce platforms, customer service providers, credit and debit card processing companies, chat providers and shippers. Such service providers may be provided with access to your personal information to perform the functions for which they have been retained. Briogeo requires its service providers, who provide services on our behalf (such as our e-commerce platform) to maintain the privacy and security of your personal information.

We may disclose any information, including personal information, we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request, to protect ourselves from fraudulent or illegal activity, and to defend against legal claims.

In the past twelve (12) months, depending on the individual circumstances, we have shared the categories of personal information collected in Categories [A-B, D-G] with the following categories of third parties: advertisers.

In the past twelve (12) months, depending on the individual circumstances, we have not disclosed the categories of personal information collected in Categories [A-G] with outside organizations or entities who are not service provider or contractors providing services on our behalf.

Your rights regarding your personal information

● You have the right to request that the Company disclose the personal information that the Company collects, uses, shares and discloses about you. You may “request to know”: (i) the categories of personal information that the Company has collected about you; (ii) the categories of sources from which the personal information is collected; (iii) the business or commercial purpose for collecting or sharing your personal information; (iv) whether any categories of personal information were disclosed for a business purpose to third parties and the categories of third parties with whom the Company discloses your personal information; and (v) the specific pieces of personal information that the Company has collected about you. Your request may pertain to the personal information collected about you on or after January 1, 2022. If your request covers a time period beyond twelve [12] months from the date of your request, the Company may deny your request as to that time period where it would be impossible for the Company to provide you with the information or involve disproportionate effort. The Company may deny your request to search for certain information under certain circumstances (e.g., where the Company retains the information solely for legal and compliance purposes).

● You have the right under certain circumstances to receive specific pieces of your personal information in a format that is understandable, and to the extent technically feasible, in a structured, commonly used, machine readable format that allows you to transmit the information to another entity.

● You have the right to correct inaccurate personal information.

● You have the right to request deletion of personal information under certain circumstances. For example, we may not be required to delete personal information if we need to retain the information to complete the transaction for which the personal information was collected, perform on a contract with us, or to comply with a legal obligation. In addition, we may delay deletion with respect to data stored on an archived or backup system, until the archived or backup system relating to that data is restored to an active system or next accessed or used for a sale, disclosure, or commercial purpose.

● You have the right to know what information is shared with third parties, and to whom and to opt out of sharing for cross-context behavioral advertising. We do not sell your personal information.

● You have the right not to receive discriminatory or retaliatory treatment for the exercise of any of these rights. We will not discriminate or retaliate against you or refuse to provide you Products or Services because you have exercised your rights.

You may submit verifiable requests concerning any of your rights by contacting us by e-mail to**:** support@briogeohair.com by mail at the address below. We will use reasonable methods for verifying that the person making a request to know, data portability, request to correct or a request to delete is the individual about whom we have collected personal information. 

This may involve, depending on the nature of the request, confirming that the email address provided corresponds with our records concerning the individual. Additional reasonable measures may also be required to verify the identity of the person making the request depending on the circumstances. For requests to delete made electronically, you may be required to submit the request to delete, and then separately confirm that you want your personal information deleted. We will maintain a record of your request to delete. To the extent that you wish to use an authorized agent to make requests concerning the rights set forth above, you will need to provide us either with a power of attorney or, alternatively, with signed authorization to communicate with your authorized agent, and directly confirm that you provided the authorized agent with permission to submit the request.

We will (i) confirm receipt of requests to know, data portability, to correct inaccurate information or to delete within ten [10] business days of the request; and (ii) generally respond to requests to know, data portability, to correct inaccurate information or to delete within forty-five [45] calendar days of the request. If we need additional time to respond to your request beyond the forty-five [45] calendar days, we will provide you with notice explaining the reasons we need more time, and we will then take up to an additional forty-five [45] calendar days to respond to your request.

Reasonable Safeguards To Protect Your Personal Information

We are committed to maintaining the security of your personal information in compliance with all applicable laws and our policy. We take commercially reasonable steps to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

Access By Persons With Disabilities

Persons with disabilities who need assistance accessing this CPRA Privacy Notice may contact us as provided for above, and depending on your individual needs, the Company will grant reasonable requests to furnish this policy in an alternative format.

Children

Our Site is not intended for use by children under 13 years of age. No one under age 13 may provide any information to us through the Site. We do not knowingly collect or use personal information from children under 13. If you are under 13, do not access, use or provide any information on the Site or on or through any of its features. 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. We do not sell any personal information, including the personal information of minors under 16 years of age.

Notice of Financial Incentive to California Consumers

We may, at times, offer you various financial incentives such as loyalty programs, discounts and special offers when you provide us with contact information and identifiers such as your name and email address. When you sign-up for our loyalty program, email list or other discounts and special offers, you opt-in to a financial incentive. You may withdraw from a financial incentive at any time by opting out from our email or closing your loyalty member account. Generally, we do not assign monetary or other value to personal information, however, California law requires that we assign such value in the context of financial incentives. In such context, the value of the personal information is related to the estimated cost of providing the associated financial incentive(s) for which the information was collected.

California Shine the Light Law/Online Privacy Protection Act

California Civil Code §1798.83 provides that California residents may request certain information concerning the disclosure of personal information to third parties for direct marketing purposes. Pursuant to California Business Code §§22575-22579, you may review and request changes to any of your personal information that we have collected. Should you wish to request this information or exercise these rights, please reach us at the contact information provided below.

If you permit us to share your personal information, we do not control and are not responsible for third party tracking technologies that may be used on our Site. Such third parties may serve you content based on tracking you across different websites. You consent to potentially encountering third party tracking technologies when you use our Site.

Do Not Track Signals and Global Privacy Controls 

We recognize Do Not Track Signals and Global Privacy Controls associated with your browser. If your browser has these signals enabled, we will only lodge strictly necessary cookies if your browser permits those cookies.

Revisions to This CPRA Privacy Notice

We may update this CPRA Privacy Notice at any time, by posting the amended version on this Site including the effective date of the updated version. By accessing the Site or purchasing products after we make any such changes to this CPRA Privacy Notice, you are deemed to have accepted such changes. Please check this CPRA Privacy Notice regularly, and before you submit additional personal information via the Site.

Contact Us

If you have questions or comments regarding this CPRA Privacy Notice or if you would like to exercise your rights send us an email to support@briogeohair.com; or send us regular mail to 135 MADISON AVE, 5TH FLOOR, NY, NY 10016. 

Effective Date: January 1, 2020

Last Updated: December 4, 2023

BRIOGEO PRIVACY NOTICE UNDER VIRGINIA, COLORADO AND CONNECTICUT LAW

This State Privacy Notice applies to the collection of personal data from residents of Virginia, Colorado and Connecticut law on or after the effective date of privacy laws in those states to the extent applicable. This State Privacy Notice supplements the information above to provide those residents with rights and information required in the afore-mentioned states. 

In addition to the disclosures in our notice above, you may exercise your rights under those laws, including, as applicable, rights to access, correct, delete, portability, to opt out of sale, profiling or targeted ads by sending us an email to support@briogeohair.com; or send us regular mail to 135 MADISON AVE, 5TH FLOOR, NY, NY 10016. You have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial. Your rights will be determined by the particular state you live in.

  1. BRIOGEO NOTICE OF COLLECTION OF PERSONAL DATA AND PRIVACY POLICY UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

This Notice of Collection of Personal Data and Privacy Policy (“GDPR Privacy Notice”) applies to the collection of personal data from residents of the European Union on or after May 25, 2018. This GDPR Policy Notice supplements our “Privacy Notice” above to provide European Union residents with information and rights required by the General Data Protection Regulation (GDPR).

This GDPR Privacy Notice describes the types and categories of personal data we collect, the business purposes for which we collect, use and share your personal information, with whom we share it, the lawful basis for processing and your rights in personal data under the GDPR.

For purposes of this GDPR Privacy Notice, we refer to personal data according to the following definition given in the GDPR: “personal data” means any information relating to an identified or identifiable natural person (“Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

When we refer to “processing” in this GDPR Privacy Notice, we means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

By submitting personal data to us, or purchasing our products or using our online services, you consent to the collection, use, sharing and disclosure of such information as set forth in this GDPR Privacy Notice, as it may be updated from time to time.

What categories of personal information do we collect about you?

  1. We may collect personal information from you in various ways including:

    1. ● when you provide us with information (e.g., through your communications with us by email or telephone or through our Site and our Join Our Rewards program, Sign Up/Set An Account or Sign Up for our newsletter, or on our social media pages);

    2. ● when you communicate with us concerning our products;

    3. ● purchase one of our products; and

    4. ● through automated means when you use our website including by use of “cookies” and other similar tracking technologies.

We collect the following categories of personal information:

  • Identifiers: this information may include your name and contact details (including mailing addresses, telephone numbers, email addresses, IP address, browser identifier, geolocation data and other identifying information you provide to us). For example, we may collect your name and email address when you join our mailing list to receive information on our products.

  • Customer Information: this information comprises any information that identifies, relates to, describes or is reasonably capable of being associated with you or your household in our records. Examples include your payment related information that we use to charge for our products, including debit or credit card numbers. All debit or credit card transactions are processed by our third-party payment vendors. We do not collect, store or maintain any credit card or debit card information on or through our website after the transaction is processed and verified. Instead, it is transiently collected, shared with and processed through these third-party payment vendors using their platforms. We do not share your credit or debit card information with any vendors, other than our third-party payment vendors. Some personal information in this category may overlap with other categories.

Special Categories of Personal Data: This includes demographic information, such as age, race, gender or ethnicity, or medical information related to our products, that you may voluntarily provide to us. (Note, we never request or require that you provide us with any special categories of personal data. If you decide to share this information with us, we may maintain a copy of the communication for the purposes for which you provided the information to us (e.g., to resolve a complaint, make a refund).

  • Commercial Information: this category includes information concerning the products you purchased and your purchasing history and tendencies.

  • Internet and other electronic history: this category comprises electronic information concerning your use of the website (www.briogeohair.com) and dependent pages (the “Site”). This information may include information we automatically collect as you browse the Site, including your IP address, device type or client/user identifier, browser type/identifier, operating system, pages visited and other similar information. We use first party cookies and services provided by third parties using third party cookies or tracking technology to provide us with information concerning your website activity and to provide you with advertising. Third parties may use third party cookies to collect information when you visit their websites for their own business purposes. Our participation in advertising campaigns is described more fully in our privacy policy. We use information from cookies and tracking technologies (e.g., pixels, web beacons) in order to improve and customize your browsing experience, for analytics and metrics about your visits to our Site (e.g. the information concerning the length of your visit to our Site, where your visit originated from) and for marketing our products to you. Other cookies are necessary for the Site to function properly or enhance the Site’s performance and functionality. If you click “Accept” to the cookie banner, you consent to all cookies, including third party cookies. In addition to not clicking “Accept,” if you do not want cookies placed in your browser, you may be able to turn that feature off or permit certain types of cookies by changing the settings on your browser. Please consult your Internet browser’s documentation for information on how to do this. However, if you decide not to accept essential or functional cookies, the Site may not function properly and some features may not work as they were intended.

  • Geolocation data: we may determine your approximate geographic location through your IP address in order to market our products at physical locations, such as retailers, that are nearby to you. Geolocation information is provided to us for use for marketing purposes based on third party marketers and e-commerce platforms that monitor usage of our Site. If you do not want us to collect geolocation data, you may change the settings on your mobile device, which lets you choose how and whether your location is shared with us.

  • Inferences drawn from information you provide to create a personal profile concerning your consumer preferences, characteristics, predispositions, behavior, and attitudes. We may accumulate the information you provide to develop a consumer profile concerning your behavior and interests, including for our marketing and advertising purposes, and to improve our products.

Our Business Reasons For Collecting And Processing Your Personal Information

We collect and process personal information for the legitimate business purposes of Briogeo. These purposes include to provide you with products, to fulfill the purpose for which you provided us with your personal information, to communicate with you, to perform on a contract between you and the Company, to market our products to you, to process payment and shipping and for account management, to improve the functionality and effectiveness of our websites, to protect the security of our website, to protect against fraud, and to comply with applicable law, rules or regulations.

Who we share your personal information with

We do not sell your personal information to third parties.

In some instances we may retain other companies and individuals to perform functions on our behalf, including, but not limited to, web hosting platforms, e-commerce platforms, customer service providers, and shippers. Such third parties may be provided with access to your personal information to perform the functions for which they have been retained. Briogeo requires its service providers, who provide services on our behalf (such as our e-commerce platform) to maintain the security of your personal information.

We may also disclose your personal information to third party advertisers and advertising networks.

We may disclose any information, including personal information, we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request, to protect ourselves from fraudulent or illegal activity, and to defend against legal claims.

What are Briogeo’s lawful basis for processing your personal data

Briogeo is committed to processing personal data only where there is a lawful basis:

● where you have given consent to the processing of your personal data for one or more specific purposes. Where the sole basis for our use of the personal data is your consent, you have the right to withdraw your consent at any time;

● where processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;

● where processing is necessary for compliance with a legal obligation to which Briogeo is subject;

● where processing is necessary for the purposes of the legitimate interests pursued by Briogeo or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data. Briogeo’s legitimate interests are to effectively manage our business and customers, market, sell and deliver our products, including providing you with advertising content and opportunities, manage your account, improve our services and products, maintain the security of our Site, and comply with our legal obligations.

● processing of special category personal data shall only occur where you have given explicit consent to the processing of the personal data for one or more specified purposes or where permitted by applicable law. (Note, that we do not ever request or require that you provide us with special category data)

Your rights regarding your personal data 

Under the GDPR, you have the following rights in personal data held by us:

  1. the right to access your personal data and request certain information concerning our use of your personal data, such as an explanation of the purpose of the processing, categories of personal data processed and disclosure of third parties with whom Briogeo shares the data;

  2. the right to rectify inaccuracies in your personal data or to ensure that it remains up to date;

  3. the right to erasure of your personal data under certain circumstances. For example, you may request erasure if the data is no longer needed in connection with the reasons it was collected or processed or if you withdraw your consent to further processing. Briogeo may deny your request where it is required or permitted by law to retain your personal data or when we need to retain your information in connection with the exercise or defense of legal claims;

  4. the right to restrict our use of your data where you contest the accuracy of the data in order to permit time to rectify the inaccuracies and in other circumstances;

  5. the right to data portability by requesting a copy be provided in a structured, commonly used and machine-readable format and/or requesting that Briogeo transmit your personal data to a third party where technically feasible;

  6. the right to object to our use of your personal data where you contest that the processing is necessary for the purposes of Briogeo’s legitimate interests. Briogeo may deny your request because it has compelling legitimate business interests or in connection with the exercise or defense of legal claims. You also have the right to advise us at any time that you no longer wish to receive direct marketing materials from Briogeo and we will no longer use your personal data for marketing purposes; and

  7. the right to bring a complaint before the applicable governmental privacy regulator.

We will take action on your requests concerning any of your rights without undue delay and in any event within one month of receipt of the request. We may extend that time period by two further months where necessary, taking into account the complexity and number of the requests. If we need more time, we will inform you of any such extension within one month of receipt of the request, together with the reasons we need more time. The information you requested shall be provided by electronic means where possible, unless you request otherwise.

In addition, regardless of where you live, you have choices available to you through the device or browser you use to access the Site. For example:

• The browser you use lets you control cookies or other types of privacy settings.

• Your mobile device lets you choose how and whether your location is shared with us.

Reasonable Safeguards To Protect Your Personal Information

We are committed to maintaining the security of your personal information in compliance with all applicable laws and our policy. We take commercially reasonable steps to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

Children

Our Site is not intended for use by children under 13 years of age. No one under age 13 may provide any information to us through the Site. We do not knowingly collect or use personal information from children under 13. If you are under 13, do not access, use or provide any information on the Site or on or through any of its features. 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. 

Do Not Track Requests

We recognize Do Not Track Signals and Global Privacy Controls associated with your browser. If your browser has these signals enabled, we will only lodge strictly necessary cookies if your browser permits those cookies.

Revisions to This GDPR Privacy Notice

We may update this GDPR Privacy Notice at any time, by posting the amended version on this Site including the effective date of the updated version. By accessing the Site or purchasing products after we make any such changes to this GDPR Privacy Notice, you are deemed to have accepted such changes. Please check this GDPR Privacy Notice regularly, and before you submit additional personal information via the Site.

How Long Do We Retain Your Data

We do not retain your personal data for longer than is necessary to fulfill the business purposes for which the information is being collected or processed or in order to comply with applicable legal or regulatory requirements. Personal data will be maintained for at least their minimum time period required retention under Briogeo’s records retention schedules. 

Contact Us

If you have questions or comments regarding this GDPR Privacy Notice or if you would like to exercise your rights, please send us an email to support@briogeohair.com or by mail at 135 MADISON AVE, 5TH FLOOR, NY, NY 10016.

Effective Date: May 25, 2018

Last Updated: December 4, 2023

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