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Privacy Policy

Updated June 2, 2020

OVERVIEW

The Beauty Circuit, LLC (“TBC,” “we” or “our”) respects your privacy and your right to determine how your information is shared. TBC’s virtual event platform accessed through our website at www.thebeautycircuit.us (the “Website”) provides a safe and convenient online venue for individuals and beauty and personal care professionals (including their associates and staff) to meet, network with, and learn from industry experts and vendors during prescheduled online events (“Events”), to develop professional relationships, and to purchase products at Event prices (the “Service”).

This Privacy Policy (“Privacy Policy”) is part of our Terms of Service (“TOS”), which describe the conditions of use, the limitations of liability, and other factors you  are required to agree to in order to use the Website and the Service as well as the types of information we collect, how we use it, with whom we share it, and the choices you (“you” or “your”), our users, can make about our collection, use and disclosure of your information and the measures we take to protect the security of your information. Please be sure to read the TOS and Privacy Policy carefully. You are welcome to contact us with your questions about these matters at info@thebeautycircuit.us.

You understand that TBC operates the Website and the Service for the purpose (the “Intended Purpose”) of facilitating introductions and the exchange of information between Event attendees (“Attendees”) who wish to meet and share contact and other information with the vendors and other participants in each Event (“Exhibitors”) as well as any Event Sponsors (“Sponsors”).

BY USING OUR WEBSITE OR SERVICE, OR BY SUBMITTING INFORMATION THROUGH OUR WEBSITE OR SERVICE, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY AND YOU EXPRESSLY CONSENT TO THE PROCESSING OF YOUR INFORMATION ACCORDING TO THIS PRIVACY POLICY.

Please review this Privacy Policy periodically, but at least each time before you attend an Event, as we may update it from time to time to reflect changes in our data practices. Our most recent TOS can be found at www.thebeautycircuit.us/TOS. Our most recent Privacy Policy may be found at www.thebeautycircuit.us/privacy.

PERSONAL INFORMATION

As used in this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable natural person (i.e., an individual). It does not include information that is not associated with an identified or identifiable individual or information or information that is reported in the aggregate (provided that such aggregated information is not identifiable to a natural person), and does not include information as to which identifying characteristics have been removed without means reasonably likely to be used by any person to re-identify the natural person directly or indirectly indicated.

HOW WE COLLECT INFORMATION

We may obtain information about you that you submit voluntarily, including when you sign up for or participate in an Event or when you call or email us, communicate with us through social media, or submit a website form requesting information about us or our Services.

This information is Personal Information since it identifies you. Our legal basis for processing this information is your consent. It may include any of the following:

  • Information that identifies you, such as your name, password for the Website, email address, street address, and phone number.
  • Demographic Information, such as zip code, country, business affiliation, years in the industry, skills, certifications, degrees, or membership in particular organizations. We do this to help you connect with Exhibitors and Attendees and to provide you with information that may be interesting or useful to you.
  • Preference Information, such as preferred time zones, or manner of using the Services. We do this to personalize your experience on the Website.
  • Information stored in your social media profile that you authorize us to access when you use your social media profile to execute features on the Service, such as the ability to log into the Service using your social media profile credentials.

We also may obtain information about you from Exhibitors and other third parties and from publicly available information. This information includes the same types of Personal Information described above that you may voluntarily provide to us. Third parties may have privacy policies that may differ from this Privacy Policy. We do not control the data privacy or protection policies of third parties, and we are not responsible for the privacy practices of these third parties. Our legal basis for processing this information is our legitimate interests, namely monitoring and improving the Website and Services and facilitating the Intended Purpose.

We may also collect certain information by automated means, such as:

  • Information about the devices you use to access the Website (such as the IP address and the device, browser and operating system type).
  • Pages and URLs that referred you to our Website, and pages and URLs that to which you may exit from our Website, and search terms that you used to reach the Website.
  • Dates and times of visits to the Website, and length of time using the Services.
  • Information on actions taken on the Website, such as page views, site navigation patterns or application activity.
  • The general geographic location (such as country and city) from which you access the Website.
  • Cookies and web beacons, as described more fully below under “About Cookies, Web Beacons, Tracking Choices and Third-Party Service Providers.”

Our legal basis for processing this information is your consent and our legitimate interests, namely monitoring and improving our Website and Services.

HOW WE USE THE INFORMATION WE COLLECT

We may use the information we obtain about you to:

  • Create, manage and maintain your account on the Website.
  • Provide you with the Services.
  • Manage your participation in Events.
  • Maintain a record of the Events in which you participate.
  • Enable you to interact with other Event Attendees and Exhibitors.
  • Provide administrative notices or communications applicable to your use of the Service and the Website (which are not subject to opt out).
  • Respond to your questions and comments and provide information and support to you as necessary.
  • Operate, evaluate and improve our business and the products and services we offer.
  • From time-to-time, to market to you our products and services and those of our affiliates, partners and third parties.
  • Analyze and enhance our marketing communications and strategies (including by identifying when emails we may send to you have been received and read).
  • Analyze trends and statistics regarding access to and use of the Website.
  • Protect against and prevent fraud, unauthorized transactions, claims and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users.
  • Enforce our Terms of Service.
  • Comply with applicable legal requirements and our policies.

We also use Cookies, web beacons and certain technical information about your computer and your access of the Website (including your IP address) in order to operate, maintain and manage our Website and improve the Services as necessary. We collect this information by automated means, as described more fully below under “About Cookies, Web Beacons, Tracking Choices and Third-Party Service Providers.”

We may use aggregate and/or anonymize data to create data compilations for statistical purposes and any other uses without restriction. This includes reporting information or marketing the Services to Exhibitors and Attendees and prospective Exhibitors and Attendees of future Events. We may also use aggregate/anonymous data to analyze Website usage and customize the Website’s content, layout and Services, to improve the Website, and to better meet the needs of Exhibitors and Attendees. Information that is in “aggregate/anonymous” form refers to non-identified information or information that is reported in the aggregate or which has had identifying characteristics removed in such a manner that it is not reasonably likely that any natural person could be identified from such data.

ABOUT COOKIES, WEB BEACONS, TRACKING CHOICES AND THIRD-PARTY SERVICE PROVIDERS

A “cookie” is a text file that websites send to a user’s device to uniquely identify the user’s browser or to store information or settings in the browser. We use cookies and other similar technologies to ensure that everyone who uses our Website has the best possible experience. We use session cookies to make it easier for you to navigate our Website. A session ID cookie helps you to navigate the Website but expires when you close your browser.  “Session” cookies do not track where you have been on the internet and do not gather information about you.

We also use “Persistent” cookies, which are saved on your device for a fixed period of time after you close your browser and are activated each time you visit the Website. We use these cookies to recognize you as an existing user and to enable us to serve secure pages without asking you to sign in repeatedly. We may also use cookies to store non-personally identifying information such as your preferences to ensure the efficiency of our Services.

We permit a number of third-party cookies on the Website. For example, we use web analytics services provided by third parties, such as Google Analytics, which use cookies to collect non-personal information about details of our users’ visits to the Website (including IP addresses) and the resources they access on the Website. These third-party web analytics services provide us with reports based on this information in order to help us understand how users engage with the Services.

We may use web beacons to evaluate the success of our communications. A “web beacon” (a/k/a “pixel tag” or a “clear GIF”) is a small, often transparent, graphic image, sometimes, used in combination with cookies, placed on a web site or in an e-mail and used to detect information about the visitor to the website or recipient of the email, such as which browser and operating system is being used, if the email has been read by the recipient, when it was read, how many times it has been opened, if it has been forwarded to others,

If you do not wish us to collect cookies, you may set your browser to refuse cookies, or to alert you when cookies are being sent. Unless you have adjusted your browser setting so that it will refuse cookies, your system will continue to accept cookies when you direct your browser to our Website. PLEASE NOTE THAT IF YOU SET YOUR BROWSER TO REFUSE COOKIES YOU MAY BE UNABLE TO ACCESS CERTAIN PARTS OF THE WEBSITE. This is because our Website security requires that we recognize you as an Attendee or Exhibitor as you navigate the Website and move from page to page or use the communication tools provided to communicate with other Attendees or Exhibitors or view Website content. Without cookies enabled, you appear to the Website as a new, unrecognized user each time you navigate to a new page or request that the Website perform a function.

There are many neutral resources on the Internet that can provide you guidance regarding cookies, how to manage them, and how to delete them if you wish, including https://en.wikipedia.org/wiki/HTTP_cookie, www.allaboutcookies.org and www.aboutcookies.org. Most Internet browsers enable you to erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

SENSITIVE PERSONAL INFORMATION AND INFORMATION SHARING

We do not require that you provide Sensitive Personal Information in order to use the Services. “Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, political opinion, religious or philosophical beliefs, trade union membership, genetic data, biometric data where processed to uniquely identify a person, any information that concerns medical or health conditions or sex life, or information relating to the commission of a criminal offense.

When you register for an Event, you will be given an opportunity to create a profile that includes certain Personal Information. While some Personal Information is mandatory, you are not required to add Sensitive Personal Information to your profile. However, disclosing certain optional information that may also be Sensitive Personal Information may result in a better user experience for you during an Event if, for example, Exhibitors have a fuller picture of you as an Attendee.

YOU ARE ADVISED THAT BY PROVIDING PERSONAL INFORMATION, INCLUDING SENSITIVE PERSONAL INFORMATION, YOU ARE PROVIDING YOUR EXPRESS CONSENT TO SHARE SUCH INFORMATION IN A MANNER CONSISTENT WITH THIS PRIVACY POLICY.

You are further advised that we may record or maintain records of all information shared through the Website, including, but not limited to, chat room discussions and voice or video interactions. We do this for legal reasons, to improve customer service, to ensure a general climate of civility among Website participants, to monitor compliance with the Terms of Service, to assist Exhibitors in evaluating participation in the Event and help them understand their audience, and to discourage abuse of the Website, but we are not obliged to collect or maintain any such information. We may make your Personal Information available to Exhibitors whether or not you interact with them at the Event, but we will not make such information available to other parties except in an aggregate form that does not disclose personal information, unless you have opted in to a mailing list or other marketing opportunity.  Notwithstanding the foregoing, if you violate the Terms of Service, and especially if you use the Website in a manner that we believe threatens, harasses, bullies, or discriminates against other users, we may provide your Personal Information, including transcripts of your Website interactions, to law enforcement or disclose it in response to legal requests.

We will comply with all requests to disclose your personally identifiable information when required by law to do so. This may include providing such details in response to a request by law enforcement, in response to a court order, or in compliance with a subpoena or discovery request received in association with litigation. We may also disclose such information to support any claims that we make that our Terms of Service have been breached.

INFORMATION SHARED WITH THIRD PARTIES

We may share your information with third-party contractors or service providers to provide you with the services that we offer you through our Website; to provide technical support; or to provide specific services in accordance with your instructions. We may request that such third parties not use your information other than to provide the services requested by us, but we do not monitor compliance with such requests, and we are not responsible for any disclosure of your Personal Information by any third party.

Although we do not currently have any subsidiaries, joint ventures, parent company, or other companies under a common control (collectively, “Affiliates”), we may in the future. We may share some or all of your information with our Affiliates, in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company or our assets, we may include some or all of your Personal Information as part of the assets sold.

You agree to hold TBC harmless with respect to any information that you provide to us or that we gather in connection with your use of the Services and which we share with any other party as permitted in this Privacy Policy, or which is used or disclosed to others by any third party.

OPTING OUT OF MARKETING COMMUNICATIONS

By registering for an account with TBC, you authorize us to send you Event invitations, newsletters, marketing information, and other communications at the e-mail address you have provided. If you do not wish to receive such communication, you may UNSUBSCRIBE from our mailing list at any time by following the simple instructions located at the bottom of each mailing. If for some reason the unsubscribe function does not work on your device, please email info@thebeautycircuit.us with your request to unsubscribe.

We are not responsible for communications that you may receive from third parties, including Exhibitors. You should refer to such parties’ policies to unsubscribe from their communications if you wish to do so, and you should review their separate privacy policies before sharing information with them.

We are not responsible for the consequences of following any external or third-party links that may be presented by Exhibitors or others during an Event or that you discover in or follow from the Website or for any content on websites, applications, or materials so linked.

HOW WE PROTECT PERSONAL INFORMATION

Once we have received your information, we will use our internal procedures and the security features built into the Website prevent unauthorized access to your Personal Information. However, no transmission of information via the internet is completely secure, and we cannot guarantee the security of your Personal Information transmitted to our Website. As a Website user, you understand and agree that you assume all responsibility and risk for your use of the Website, the internet generally, and anything you post or access on or though the Website, as well as for your own conduct on the Website.

You should take steps to safeguard your TBC username and password at all times and not share that information with anyone. You should also log off from and close your browser window when you have finished your visit to our Website. Please note that we will never ask for your TBC account password via email.

We have a security incident response program designed to promptly respond to and escalate any potential privacy or security incident. If we learn of a security incident, we will take any action required by applicable law.

ONWARD TRANSFER

The Website is hosted and the Service is provided in the United States of America. In the performance of our Service and business operations, Personal Information we collect or receive may be stored or transferred internationally. If you are located in the European Union (“EU”), you should be aware that your personal information will be processed outside of the EU, including in the United States. Such international transfers of your personal information are made pursuant to appropriate safeguards in the US and standard data protection clauses adopted by the European Commission.

We will endeavor to obtain assurances that any service provider or agent outside the United States will provide at least the same level of privacy protection as is required by this Privacy Policy and will notify us if it makes a determination it can no longer meet this obligation.

DATA INTEGRITY AND PURPOSE LIMITATION

We endeavor to use Personal Information only in ways that are compatible with the purposes for which it was collected and authorized by you. We will take reasonable steps designed to ensure that only Personal Information that is relevant to its intended use, accurate, complete, current, and otherwise reliable in relation to the purposes for which the information was obtained is used by us for as long as we retain possession of such information. Our personnel have a responsibility to assist us in maintaining accurate, complete and current Personal Information. We endeavor only to process Personal Information that is relevant to our Services, and for purposes compatible with those for which the Personal Information was collected; wherever possible, such Personal Information is non-identified.

UPDATING AND CORRECTING YOUR INFORMATION

If you create an account through our Website and register for an Event, you may access, update and amend certain Personal Information included in your online account at any time prior to the Event by logging into your account and making the necessary changes.

You may choose to deactivate your account at any time. When you deactivate your account, you will be logged out of the Website, and you will no longer be able to log into the Website. We will delete registrations you have started or completed for upcoming Events, but we will not delete information you provided when registering for or participating in a concluded Event as this information has already been shared with other Event participants.

Any amendments, corrections or deletions will be reflected in active user databases as soon as reasonably practicable; however, we may retain all Personal Information previously entered and now contained in backups and archives and may access and use such information for fraud and abuse prevention, analytics, fulfillment of legal functions and obligations, prevent fraud, resolve disputes, troubleshoot problems, assist with investigations, enforce our Terms of Service, and take other actions not prohibited by law.

You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy, and you agree that we are under no obligation to delete or modify information that you have previously chosen to provide us if you have not instructed us to take such action. We have no authority and will not seek to modify information already disclosed to third parties and in their possession.

ADDITIONAL USER RIGHTS UNDER EU DATA PROTECTION

While nothing in this Privacy Policy is intended to subject TBC to jurisdiction anywhere other than as described in the Terms of Service, because TBC operates internationally, we have provided the following explanations to assist you if you are using our platform in the EU.

Your rights under applicable EU law regarding the Personal Information you have provided may include the following:

  • The right to access. You have the right to access your information. Please contact TBC’s Data Protection Officer at info@thebeautycircuit.us if you wish to access the personal information TBC holds about you.
  • The right to rectification. If the information TBC holds about you is inaccurate or incomplete, you have the right to ask us to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the data. Please contact our Data Protection Officer if you need us to rectify your information: info@thebeautycircuit.us.
  • The right to erasure. This is sometimes called ‘the right to be forgotten’. If you want TBC to erase all your personal data and we do not have a legal reason to continue to process and hold it, please contact our Data Protection Officer: info@thebeautycircuit.us.
  • The right to restrict processing. You have the right to ask TBC to restrict how we process your data. This means we are permitted to store the data but not further process it. If you want Us to restrict processing of your data, please contact our Data Protection Officer: info@thebeautycircuit.us.
  • The right to portability. TBC must allow you to obtain and reuse your personal data for your own purposes across services. Please contact our Data Protection Officer at info@thebeautycircuit.us if you want information how to port your data elsewhere. This right only applies to personal data that you have provided to Us as the Data Controller. The data must be held by us by consent or for the performance of a contract.
  • The right to object. You have the right to object to TBC processing your data even if it is based on our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purposeless of statistics. If you wish to object please contact our Data Protection Officer: info@thebeautycircuit.us.
  • The right to withdraw consent. If you have given us your consent to process your data but change your mind later, you have the right to withdraw your consent at any time, and TBC must stop processing your data. If you want to withdraw your consent, please contact our Data Protection Officer: info@thebeautycircuit.us.
  • The right to complain to a supervisory authority. You have the right to complain to the applicable supervisory authority in your country if you feel that TBC has not responded to your requests to solve a problem. For more information about how to locate your supervisory authority, go here: https://gdpr-info.eu/art-51-gdpr/.

TBC will assist you in exercising your data privacy rights to the extent required by applicable law. Unless prohibited by applicable law, we reserve the right to charge a reasonable fee to cover costs for providing copies of Personal Information that you request.

ADDITIONAL PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at info@thebeautycircuit.us.

If you are under 18 years of age, reside in California, and have a registered account with us, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us at info@thebeautycircuit.us, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from our systems.

ADDITIONAL PRIVACY RIGHTS FOR NEVADA RESIDENTS

Nevada law (SB 220) permits customers in Nevada to opt-out of the sale of certain kinds of personal information. We do not sell your personal information to third parties except as provided herein. If you are a Nevada resident and have questions, please contact us at info@thebeautycircuit.us.

DISPUTES AND CHOICE OF LAW AND LOCATION FOR RESOLVING DISPUTES

If you believe that we have not adhered to the Privacy Policy, please contact our Data Protection Officer via email at info@thebeautycircuit.us. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.

The choice or law and forum for resolving any dispute in connection with this Privacy Policy are set forth in the Terms of Service at www.thebeautycircuit.us/TOS.

THIRD PARTIES NOT GOVERNED BY THIS PRIVACY POLICY

Please be aware that we are not responsible for the privacy practices of such other sites that may be linked on our Website or of Participating Organizations to which you or we may provide your data. This Privacy Policy applies only to information collected on our Website.

CHILDREN’S PRIVACY

TBC abides by the Children’s Online Privacy Protection Act of 1998 (COPPA). We do not seek or willingly collect information on children under the age of 13. If we discover that a child under the age of 13 has signed up for an account and we have collected information in connection with that account, we will terminate any such account at once and delete that information from our system.

PRIVACY POLICY UPDATES

If we decide to make material changes to our Privacy Policy, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by updating the date at the top of the Privacy Policy. Therefore, we encourage you to check the date of our Privacy Policy whenever you visit the website for any updates or changes.

Any material changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on the Website. What constitutes a “material change” will be determined at our sole discretion, in good faith and using common sense and reasonable judgment.

Please note that at all times you are responsible for updating your Personal Information to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid or incapable of delivering to you the notice described above, our sending the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice.

We understand that changes to this Privacy Policy may affect your decision to use our Service or the Website. You have the option to deactivate your account for any reason. Continued use of the Website following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

CONTACT US

If you have any questions or comments about this Privacy Policy or our use of your personally identifiable information, please contact our Data Protection Officer via email at info@thebeautycircuit.us.