HAMMER & NAILS SALON GROUP LLC Privacy Policy

EFFECTIVE DATE:  October 5, 2018

Hammer & Nails Salon Group LLC, “we,” “us,” or “our”) values your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our website, www.hammerandnailsgrooming.com  (the “Site”), visitors to Hammer & Nails Shops, and the services available through our Site, and how we use and disclose that information. This Policy does not apply to a franchisee’s collection, use, and disclosure of your information, except as described in this policy with regard to data sharing and change of a franchisee.

By visiting the Site, or using any of our services, you acknowledge that your personal information will be handled as described in this Policy. Your use of our Site, or services, and any dispute over privacy, is subject to this Policy and our Terms of Use, including its applicable limitations on damages and the resolution of disputes. The Terms of Use are incorporated by reference into this Policy.

1. THE INFORMATION WE COLLECT ABOUT YOU

We collect information about you directly from you and from third parties, as well as automatically through your use of our Site.

Information We Collect Directly From You. The information we collect from you depends on how you use our Site, App, and Services.

• To Sign Up for a Service Online.To sign up for a service at a Hammer & Nails Shop through our Site, you must provide us with your name, email address, phone number, and the shop you would like to use for your service.
• To Schedule or Purchase Services Online. To create an account to book online or to purchase services online through our Site, you must provide us with your name, physical address, email address, date of birth, your phone number, your payment and billing information, and your username and password. If you complete a membership agreement, we also collect this information. If you do not provide this information, you will not be able to create an online account, complete a membership agreement, or make a purchase.
  We will also collect information about the services you schedule and information about your purchases.

• When You Visit a Hammer & Nails Grooming Shop. If you sign up for a service or become a Hammer & Nails customer you must provide us or our franchisee (as applicable) with your name, physical address, email address, date of birth, your phone number, and your payment and billing information. We or our franchisee (as applicable) also will collect information about the services you schedule, details about your service frequency and goals, and information about your in-shop purchases and preferences. We or our franchisee (as applicable) will also collect information when you check in for a service, such as your name, address, email address, member number, and location. If you provide your information to a shop owned by one of our franchisees, the franchisee will share the information you provide to us – please see the Information We Collect from Franchisees section below.
• When You Express Interest in Purchasing a Hammer & Nails Franchise. If you express interest in owning a Hammer & Nails franchise, we will collect your name, physical address, email address, phone number, information about your finances, information about the location you are interested in starting your franchise, and any other information you provide to us with your submission.

• Information We Collect from Franchisees. As described above, if you visit a Hammer & Nails Grooming Shop owned by one of our franchisees, you will be providing your information directly to the franchisee. When you provide your information to a franchisee (including your in-shop sign up information, purchases you make at a shop, the franchisee will make this information available to Hammer & Nails Salon Group. The franchisee, however, handles all billing and account administration, including determining how your information is used for the franchisee’s own marketing purposes. If you register for a service at a different location from your home shop, then the owners of both shops – the one at which you completed your service and your home shop – will have access to information about your service registration and participation.

We store the information that we receive from Facebook with other information that we collect from you or receive about you. Any third-party social networking site controls the information it collects from you. For information about how a social networking site may use and disclose your information, including any information you make public, please consult the social network’s privacy policy. We have no control over how any third-party site uses or discloses the personal information it collects about you.

Information We Collect Automatically. We automatically collect information about your use of our Site through cookies, web beacons, and other technologies, including technologies designed for mobile apps. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

Site:  

• domain name;
• your browser type and operating system;
• web pages you view on the Site; links you click on the Site; your IP address;
• the length of time you visit our Site and or use our Services; and
• the referring URL, or the webpage that led you to our Site.

2. HOW WE USE YOUR INFORMATION

We use your information, including your personal information, for the following purposes:

• To provide our services to you, to communicate with you about your use of our services, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.
• To tailor the content and information that we may send or display to you, to offer location customization, and to offer personalized help and instructions, and to otherwise personalize your experiences while using the Site. For example, we will display upcoming services at your preferred shop, or we may use your location information to show you Hammer & Nails Grooming Shops in your area.
• For marketing and promotional purposes. For example, we use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products, services, service services, or other information we think may interest you.
• We use your information (typically in the aggregate) to assist us in advertising the Hammer & Nails brand on third party websites and in evaluating the success of our adverting campaigns through third party channels (including our online targeted advertising and offline promotional campaigns).
  To better understand how users access and use our Site, both on an aggregated and individualized basis, in order to improve our Site and Apps, and respond to user desires and preferences, and for other research and analytical purposes.
• To administer surveys and questionnaires, such as for market research or member satisfaction purposes.
• To develop our franchise program. For example, if you inquire about operating an Hammer & Nails franchise, we will use your information to assess your suitability for owning one of our franchises.
• To enable our franchisees to provide services to you in their independently owned and operated shops. In addition, if a franchisee leaves our franchise system, we will assist with facilitating the franchise’s transition to a new owner, including ensuring that the respective shop’s members’ personal information is transitioned to the new owner to ensure the members continue to receive services.
• To comply with legal obligations, as part of our general business operations, and for other business administration purposes.

Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Use or this Privacy Policy.

3. HOW WE SHARE YOUR INFORMATION

We may share your information, including personal information, as follows:

• Hammer & Nails Franchisees.If we collect information from you requesting services from a shop in your area, we will provide that information to the local franchisee. When you sign up for service through our Site or App or in-person at a shop, such information is hosted by Zenoti Inc. (“Zenoti”), or Booker Inc “Booker” are third party providers under contract with our franchisees. All data hosted by Zenoti or Booker is made available to the franchise owner of your home shop (if applicable). If you receive a service at a different shop from your home shop, then your data will be available to the owners of both locations. If a franchisee sells or otherwise transfers its franchise, we will transfer member information controlled by the outgoing franchisee to the successor franchisee.
• Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personally identifiable information will be subject to this Policy.
• Service Providers. We disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf. In particular our POS is hosted by Zenoti, as noted above, when you register for a service, your information is available to the owner of that particular location.

We also disclose information in the following circumstances:

• Business Transfers.If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company.  As part of the business transfer process, we will share certain of your personal information with lenders, auditors, and third party advisors, including attorneys and consultants.
• In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
• To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation.
• Aggregate and De-Identified Information. We may share aggregate, de-identified, or anonymized information about users and members with third parties for marketing, advertising, research, or similar purposes.

4. OUR USE OF COOKIES AND OTHER TRACKING MECHANISMS

We and our third party service providers use cookies and other tracking mechanisms to track information about your use of our Site and App. We may combine this information with other personal information we collect from you (and our third party service providers may do so on our behalf).

Cookies.  Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities at our Site.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.

Clear GIFs, pixel tags and other technologies.Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web or mobile application pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site and App to, among other things, track the activities of Site visitors and App users, help us manage content, and compile statistics about usage of our Site and Apps. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site, and to the extent permitted, our Apps. We also may use other analytic means to evaluate our Site and Apps. We use these tools to help us improve our Site’s and Apps’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Do Not Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third-Party Ad Networks section.

Third-Party Ad Networks. We use third parties such as network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information, including personal information, about you.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. If you are in the EU, you may opt-out of certain third party cookies that we and other websites may use for targeted advertising through the European Interactive Digital Advertising Alliance (EDAA) Your Online Choices Page or www.aboutads.info.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at https://thenai.org/.

5. THIRD-PARTY LINKS

Our Site and Apps may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.

6. SECURITY OF YOUR PERSONAL INFORMATION

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

7. ACCESS TO YOUR PERSONAL INFORMATION

You may modify personal information that you have submitted by logging into your account and updating your profile information. You may also update your information by visiting your Hammer & Nails Grooming Shop. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time.

8. WHAT CHOICES DO I HAVE REGARDING PROMOTIONAL EMAILS?

In accordance with applicable law, we will send periodic promotional emails to you. You may opt-out of promotional communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.

Our franchisees also send their own marketing emails in accordance with applicable law. If you no longer wish to receive marketing emails from our franchisees, you will need to separately opt-out of the respective franchisee’s marketing emails. We do not control, and are not responsible for, the promotional emails sent by our franchisees.

9. CHILDREN UNDER 12

Our Site, Apps, and services are not designed for children under the age of 12. If we discover that a child under the age of 12 has provided us with personal information, we will delete such information from our systems.

10. CONTACT US

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at [email protected] or by contacting your local shop.

11. CHANGES TO THIS POLICY

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site and App. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.