Effective Date: August 12, 2019
IF YOU WERE A STYLEHAUL CREATOR, VENDOR, CUSTOMER, OR EMPLOYEE YOUR PERSONAL INFORMATION MAY HAVE BEEN RETAINED BY STYLEHAUL AND/OR STYLEHAUL’S PARENT OR AFFILIATES IN ORDER TO COMPLY WITH REGULATORY RECORDS RETENTION REQUIREMENTS, FULFILL CONTRACTUAL OBLIGATIONS, TO EFFECT NECESSARY AND LEGITIMATE BUSINESS PROCESSES ATTENDANT TO STYLEHAUL’S BUSINESS OR TO TAKE APPROPRIATE LEGAL ACTION TO SECURE OR DEFEND STYLEHAUL’S RIGHTS. STYLEHAUL HAS TAKEN APPROPRIATE EFFORTS TO REMOVE NON-ESSENTIAL PERSONAL DATA FROM ITS SYSTEMS (INCLUSIVE OF ALL NON-ESSENTIAL CAMPAIGN ANALYTICAL DATA) TO COMPLY WITH GLOBAL DATA PRIVACY LAWS.
IMPORTANTLY, STYLEHAUL NO LONGER COLLECTS PERSONAL DATA. STYLEHAUL ONLY STORES PERSONAL DATA FOR REASONS CONSISTENT WITH THOSE LISTED ABOVE. WE MAY RETAIN PERSONAL DATA FOR LONGER PERIODS THAN REQUIRED BY LAW IF IT IS IN OUR LEGITIMATE INTERESTS AND NOT PROHIBITED BY LAW.
IF YOU HAVE ANY QUESTIONS OR CONCERNS REGARDING YOUR PERSONAL DATA, PLEASE CONTACT PRIVACY@STYLEHAUL.COM.
OUR PRIVACY COMMITMENT
WHAT THIS POLICY COVERS
Stylehaul is the data controller of any personal data we collect from you but may enter into a joint agreement with one of our affiliates if required for legitimate reasons. We will make decisions concerning how your personal data is processed consistent with this notice and will inform you of any changes to that processing activity. Any enquiries regarding your personal data can be submitted to: firstname.lastname@example.org.
WHO THIS POLICY COVERS
WHAT INFORMATION DO WE MAY HAVE COLLECTED ABOUT YOU?
TYPES OF INFORMATION WE HAVE COLLECTED
Personal information means information that can be used to identify you. This includes:
If you were a Stylehaul Content Creator:
Stylehaul does not process End-User data
If you were a Stylehaul Business Contact or Brand:
Some personal information is needed in order to access certain areas of the Sites and the StyleHaul Features. Providing additional information beyond what is required is entirely optional, but enables you to more easily utilize and benefit from the StyleHaul Features.
INFORMATION WE RECEIVE FROM THIRD PARTIES
If you are a Content Creator, we may receive information about your content, such as the number of views, the number of followers and the subject matter of your content from third parties such as Tubular Labs and Social Blade. We will also gather such information from social networking sites and the Internet.
We are also working closely with third parties (including, for example, business partners, advertising networks, analytics providers, search information providers,) and may receive information about you from them. From these third parties we receive:
Information about your content and information about how you engage with content
When you are purchasing products through our third party clients, such as Sephora, with your consent, those vendors may provide us information regarding your transactions in accordance with their privacy policies, but such vendors will not provide StyleHaul your payment information under any circumstances.
When you engage with our Sites through social media such as Facebook and YouTube, or other non-StyleHaul sites or applications, those sites will share personal data with us: about the content you have viewed or interacted with and about adverts within the content which you have been shown or clicked on; and other information you have given those sites permission to share.
The privacy policies for these sites and applications will contain more detail about this and how to change your privacy settings on those sites and applications.
HOW WE USE YOUR PERSONAL INFORMATION AND WHAT THE LEGAL BASIS FOR THIS USE IS
We process your personal information for the following purposes:
We keep track of your interactions with us in accordance with our data retention policies, including but not limited to your activity within the StyleHaul Features. We may make your personal information non-personally identifiable by removing characteristics (such as your name or email address) that make the information personally identifiable. This process is known as de-personalizing or anonymizing your information resulting in “Analytical Data”.
STYLEHAUL DOES NOT SELL PERSONAL DATA
Stylehaul does not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise share personal data with any affiliated or unaffiliated entities for monetary or valuable exchange.
Cookies are small pieces of information sent by a web server to a web browser which allows the server to uniquely identify the browser on each page.
We use the following categories of cookies on our Sites:
Targeting cookies or advertising cookies
These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, we may use third party companies such as Google DoubleClick to provide you with more personalised adverts when visiting other websites.
We do not knowingly collect personal information from children under 13. We take the privacy of children seriously, and encourage parents to play an active role in their children online experience at all times.
WHO WE SHARE YOUR PERSONAL INFORMATION WITH
Personal data may be shared with government authorities and/or law enforcement officials if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
We may use your personal information to send communications to you about promotions, updates, product sampling, or special offers that may be of interest to you.
We may share your personal information with carefully selected vendors and business partners, including companies that perform marketing services, product merchandising services and other business operations for us in the following categories: contract performance and payment, analytics and sentiment analysis to measure performance of a campaign, and shipping or fulfilment services for sending product .
We may also provide Analytical Data to prospective partners and other third parties.
In addition, we will share the personal information we collect from you under the following circumstances:
We share personal information relating to Content Creators using the StyleHaul Society service with brands, so that connections can be made and content can be distributed across social media channels using social media platforms and other media and in connection with the development of paid campaigns.
ADDITIONAL INFORMATION YOU SHOULD KNOW ABOUT THIRD PARTIES
If you link you Google and/or YouTube accounts to our Sites, and wish to revoke our access to your data at any time, you may do so here: https://security.google.com/settings/security/permissions.
Although we encourage such third parties to adopt and follow their own privacy policies, we are not responsible for their collection and use of your personal information.
You should refer to the privacy policies and statements of other websites or contact the respective websites to obtain information regarding their information collection, use and disclosure policies.
WHAT CHOICES DO YOU HAVE ABOUT THE COLLECTION AND USE OF YOUR PERSONAL INFORMATION?
ACCESING YOUR INFORMATION
As permitted by law, you may be permitted to access, correct, delete, opt-out of processing, request a copy of, or request information concerning the purposes for which we use your personal data by emailing us at email@example.com. Please note that we may be required to retain your information for a reasonable period of time even if you request that your data be deleted in order to comply with our local law and/or take appropriate legal action to secure or defend our rights.
StyleHaul does not sell your personal data.
OPTING OUT OF RECEIVING COMMUNICATIONS FROM US
If you no longer want to receive our newsletter, emails or other announcements or marketing communications from us, you may unsubscribe by writing to us at firstname.lastname@example.org or replying to the unsubscribe link at the bottom of our communication or otherwise following instructions in the communication.
WHAT SECURITY MEASURES DO WE TAKE TO SAFEGUARD YOUR PERSONAL INFORMATION?
We use reasonable technical, administrative and physical measures to protect information contained in our system against misuse, loss or alteration. The personal information that you provide to us is stored on servers, which are located in secured facilities with restricted access, and protected by protocols and procedures designed to safeguard such information. However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us or through the use of any of the StyleHaul Features and you acknowledge and agree that you provide such information and engage in such transmissions at your own risk. Once we receive a transmission from you, we will endeavor to maintain its security on our systems.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. If we receive instructions using your log-in information we will consider that you have authorized the instructions.
NOTIFICATION OF CHANGES
QUESTIONS? CONTACT US
MORE INFORMATION FOR INDIVIDUALS FROM THE EEA AND SWITZERLAND
a. Your data controller entity
The data controller for your information is StyleHaul, Inc.
b. Transfers of personal information outside the EEA
We operate globally, so we do need to transfer your personal information internationally. In particular, your personal information will be transferred to and processed in the United States where many of our central databases operate and may also be transferred to Singapore and Indonesia, where we have offices. Where information is transferred from StyleHaul Europe to StyleHaul Inc in the United States, StyleHaul has an intra-company agreement incorporating the EU Commission approved standard contractual clauses.
Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to email@example.com.
c. Legitimate Interests
We carry out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details below.
d. How long will you retain my personal information?
Where we process registration information, we do this for as long as you are an active user of the StyleHaul Features.
Where we process personal information for marketing purposes or with your consent, we process the information until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your information indefinitely so that we can respect your request in future.
Where we process personal information for Site security purposes, we retain it for only as long as necessary.
Where we process personal information in connection with performing a contract, we keep the personal information in line with the contractual limitation period and applicable laws on contract and payment information retention.
Where we offer online services to children over 13 in Europe or the United States we obtain parental consent where required by applicable law. Therefore if you are a parent we may ask you for certain information to verify parental consent.
f. Your rights
You have the right to ask us for a copy of your personal information; to correct, delete or restrict (stop any active) processing of your personal information; and to obtain the personal information you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this information to another controller.
In addition, you can object to the processing of your personal information in some circumstances (in particular, where we don’t have to process the information to meet a contractual or other legal requirement, or where we are using the personal information for direct marketing).
If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
These rights may be limited, for example if fulfilling your request would reveal personal information about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your personal information for other purposes, such as those set out above. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
g. How do I get in touch with StyleHaul?
We hope that we can satisfy queries you may have about the way we process your information. If you have any concerns about how we process your information, or would like to opt out of direct marketing, you can get in touch at firstname.lastname@example.org or by writing to Legal Department, 6255 W. Sunset Blvd., Suite 1450, Los Angeles, California 90028.