Last updated May 2020 

Pogi Beauty, LLC (“Pogi  Beauty” or “Company”) has created this Privacy Policy for www.OneSizeBeauty.com (the “Website”) in order to demonstrate its firm commitment to privacy (“we”, “us”, or “our” as used in this Privacy Policy may include One Size Beauty’s parent company, Luxury Brand Partners, LLC (“LBP”), and all LBP subsidiary companies and websites within the LBP family of companies).  We respect your privacy and are committed to protecting your personal information and your right to privacy through our compliance with this Privacy Policy.  This Privacy Policy describes the types of personal information we may collect from you or that you may provide when you visit the Website and our practices for collecting, using, maintaining, protecting and disclosing that information.    

This Privacy Policy applies to personal information we collect:

• On our Website and platforms.
• In email, text and other electronic messages between you and this Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.
• In certain offline formats as described herein.

It does not apply to personal information collected by:

• Us from our employees, contractors, job applicants or business contacts.
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website. 

For the purposes of the General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018 (“DPA 18”), One Size Beauty is the controller of the personal information we collect on the Website.  For the purposes of the California Consumer Privacy Act (“CCPA”), One Size Beauty is characterized as a “business” in our use of personal information and our affiliates and the third parties with which we work may act as “service providers”. 

Please read this Privacy Policy carefully to understand our policies and practices regarding your personal information and how we will treat it.  If you do not agree with our policies and practices you should not use our Website.  If you are in the European Economic Area (“EEA”) or the United Kingdom (“UK”), this Privacy Policy is provided for informational purposes only.  If you are outside the EEA or the UK, by accessing or using this Website you agree to this Privacy Policy.  This Privacy Policy may change from time to time (see Changes to Our Privacy Policy).  If you are outside the EEA or the UK, your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.    

1. CHILDREN UNDER THE AGE OF 16

Our Website is not intended for children under 16 years of age.  No one under age 16 may provide any personal information on the Website.  We do not knowingly collect personal information from children under 16.  If you are under 16, do not use or provide any information on this Website.  If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information.  If you believe we might have any information from or about a child under 16, please contact us at legal@OneSizeBeauty.com. 

1. COOKIES AND OTHER TECHNOLOGIES

We use a variety of tools on our website that collect data using both cookies or other similar technologies.  Cookies are pieces of information that a website transfers to your computer’s hard drive for record-keeping purposes.  We use cookies to track your preferences and purchases as you navigate through our Website and to save you from having to re-enter information every time you visit our Website. 

As you navigate through and interact with our Website, we may use automatic data collection technologies (including cookies and JavaScript libraries) to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and in most cases does not include personal information.  It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Recognize you when you return to our Website.

For additional information about our use of cookies and related technologies, click here. 

1. PERSONAL INFORMATION WE COLLECT

The personal information we collect directly from you on our Website may include:

• Information you provide by filling in forms on our Website or personal information you provide at the time of subscribing to our email lists or by placing orders through our Website.  We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us. 
• Your responses to surveys that we might ask you to complete for research purposes.

Name and Contact Data. Such as your first and last name, email address, postal address, phone number, and other similar contact data.

Credentials. Such as passwords, password hints, and similar security information used for authentication and account access.

Payment Data. Such as data necessary to process your payment if you make purchases, which may include your payment instrument number (such as a credit card number) and/or the security code associated with your payment instrument.

The personal information we collect will depend on the context of your interactions with us and the services, the choices you make and the products and features you use. 

The personal information we collect from you through surveys.

From time-to-time, we may request Personal Information from you via online or offline surveys. All survey participation is, of course, voluntary, and you will be able to decide what information to provide. Personal Information we collect may include:

• Identifiers, such as your name and email address;
• Responses to our surveys or polls, which may include your opinions, preferences, and other information you provide us.

The personal information we collect when you enroll in a class.

We occasionally host classes for existing or potential customers on how to use our products and services.  If you register, we will collect the following information:

• Identifiers, such as your name and email address;
• Information about your use of our products and services, current needs, and other information you may provide us to administer the class.

The personal information we may collect about you from other sources, including:

• Public databases.
• Our marketing partners.
• Social Platforms.

Examples of the personal information we receive from other sources include social media profile information, marketing leads, and search results and links, which including paid listings (such as sponsored links).

Categories of personal information we collect under the California Consumer Privacy Act (“CCPA”):

For purposes of the CCPA, we may collect the following categories of personal information from both online and offline sources:

Category	Examples
Customer Identifiers.	Name, alias, IP address, email address, password, password hint, security information used for authentication and account access, and other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal.  Civ.  Code § 1798.80(e)).	Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data.	Physical location or movements.
Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.

All personal information you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.    

1. HOW WE USE YOUR PERSONAL INFORMATION

We use personal information that we collect, or you provide to us, via our services for a variety of business purposes.  Where required bv applicable law, our processing of your personal information is justified as follows:   

• Processing is necessary to perform a contract with you or to take steps to enter into a contract at your request:
• To facilitate account creation and the logon process (including where your account with us is linked to a third-party account such as your Google or Facebook account). 
• To fulfill and manage your orders, payments, returns, and exchanges.
• To send you information about changes to our terms or policies.   

• Processing is in our legitimate interests, which are not overridden by your interests and fundamental rights:
• To present our Website and its contents to you.
• To send information you have requested, provide customer services, and investigate and respond to your concerns or complaints.
• To perform marketing, promotions and advertising, either directly or through third-parties.
• To conduct data analysis to identify usage trends and determine the effectiveness of our promotional, marketing campaigns, and advertising campaigns and to improve our products and services.
• To conduct research, surveys and similar inquiries to help us understand trends and the needs of our customers and others using our websites or other products or services.
• To administer classes regarding the use of our products and services.
• To ensure the security of the Website (for example, for fraud monitoring and prevention).
• To enforce compliance with our terms of use and other policies and to help other organizations (such as copyright owners) enforce their rights. 

• Where you give us your consent:
• Where you ask us to send marketing information and applicable law requires that we obtain your consent before sending you marketing, promotional communications, and tailored content and advertising.
• To post public testimonials about our services that use your name and testimonial.
• In cases where you give us consent, you may withdraw it at any time.

• For purposes which are required by law.
• Responding to legal requests by government or law enforcement authorities conducting an investigation                      

1. YOUR RIGHT IN RELATION TO PERSONAL INFORMATION

Data Subject Rights

Depending on your residency, you may have certain data subject rights, which may be subject to limitations and restrictions. These rights vary by jurisdiction, and may include the right to: (i) request access to and rectification or erasure of their personal data; (ii) obtain restriction of processing or to object to processing of their personal data; and (iii) the right to data portability. If you wish to exercise one of these rights, please send us your request at the contact information below. You may also have the right to lodge a complaint about the processing of your personal data with your local data protection authority. We will not discriminate against you for exercising any of these rights, for example, by charging a different price or denying goods or services. However, we may charge a different price or rate or provide a different level or quality of goods or services when that difference is reasonably related to the value provided to us by the data.

How to Exercise Data Subject Rights

If you wish to exercise your data subject rights please email hello@OneSizeBeauty.com with the phrase “Data Subject Rights” in the subject line. We will review your requests and respond accordingly. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. Additionally, if we retain your Personal Information only in de-identified form, we will not attempt to re-identify your data in response to a Data Subject Rights request.

If you make a request related to Personal Information about you, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously. If it is necessary to collect additional information from you, TA will use the information only for verification purposes and will delete it as soon as practicable after complying the request. For requests related to particularly sensitive information, we may require additional proof of identification.

If you make a Data Subject Rights request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf.

We will process your request within the time provided by applicable law.

Other California Privacy Rights

If you are a California resident, California may provide you with additional rights regarding our use of your personal information.   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 using the contact information provided below. 

If you are under 18 years of age, reside in California, and have a registered account with the services, you have the right to request removal of unwanted data that you publicly post on the services.  To request removal of such data, please contact us using the contact information provided below, 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 services, but please be aware that the data may not be completely or comprehensively removed from our systems.

1. HOW WE SHARE YOUR PERSONAL INFORMATION 

We do not share the personal information you provide us with other organizations without your consent, except as described in this Privacy Policy.  We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

• Service Providers.  We may employ companies and individuals to help provide the Website or service on our behalf or help us operate our business (such as IT, customer support, hosting, website analytics, email delivery, marketing and advertising, research, event management).   They are permitted to use your personal information only as authorized to perform these tasks in a manner consistent with this Privacy Policy.
• Payment Processors.  Any payment card information you use to make a purchase on the service is collected and processed directly by-our payment processor, and we never physically receive or store your full payment card information.   
• Advertising Partners.  We work with third party advertising companies that collect information about your activity on the Website and other online services to help us advertise our services and goods (including, through interest-based advertising), and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.
• Affiliates.  We may disclose your personal information to our subsidiaries and corporate affiliates for use consistent with this Privacy Policy. 
• Professional Advisors.  We may disclose your personal information to professional advisors such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services they render to us.
• Compliance and Protection.  We may disclose your personal information as we believe appropriate to government or law enforcement officials or private parties (a) for the compliance and protection purposes described above; (b) as required by law, lawful requests or legal process, such as to respond to subpoenas or requests from government authorities; (c) where permitted by law in connection with any legal investigation; and (d) to prosecute or defend legal claims.
• Business Transfers.  We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.     

We have not sold any of your personal information in the last 12 months.

1. DO WE USE GOOGLE MAPS?  

This Website, mobile application, or Facebook application uses Google Maps APIs.  You may find the Google Maps APIs Terms of Service here.  To better understand Google’s Privacy Policy, please refer to this link.   

If you are outside the EEA or the UK, by using our Maps API Implementation you agree to be bound by Google’s Terms of Service.  By using our implementation of the Google Maps APIs, you also agree to allow us to gain access to information about you including personal information (such as you usernames) and non-personal information (such as your location).  You agree to allow us to obtain or cache your location.  You may revoke your consent at anytime.  We use information about location in conjunction with data from other data providers.    

1. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?  

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).  No purpose in this Privacy Policy will require us keeping your personal information for longer than two years past the termination of your account.   

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.    

1. HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE?   

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process.  However, please also remember that we cannot guarantee that the internet itself is 100% secure.  Although we will take commercially reasonable efforts to protect your personal information, transmission of personal information to and from our services is at your own risk.  You should only access the services within a secure environment.   

1. EUROPEAN RESIDENTS

This Website and the services on this Website are targeted for users in the United States of America.  Any personal information you enter on this Website may be transferred outside of the EEA or the UK to countries (including the United States of America) which do not offer an equivalent level of protection to that required in the EEA and the UK.  In particular, you are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation.  By using this Website or the services, you understand and acknowledge that your personal information will be transferred to the United States of America and that it will be processed by the Company on its servers located in the United States of America as described in this Privacy Policy.

1. PERSONAL INFOMRATION BREACHES  

A personal information breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information.  You will be notified about personal information breaches when the Company believes that the breach is likely to result in a high risk of harm to you.  We will also notify the applicable data protection authority where required, unless the personal information breach is unlikely to result in a risk to your rights and freedoms.

1. 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. 

1. CHANGES TO OUR POLICY

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website home page.  If we make material changes to how we treat your personal information, we will notify you through a notice on the Website home page.  The date the Privacy Policy was last revised is identified at the top of the page.  You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

1. HOW CAN YOU CONTACT US ABOUT THIS POLICY?  

If you have questions or comments about this Privacy Policy, you may write to us by email at legal@OneSizeBeauty.com or by post to:

One Size Beauty, LLC
Att: Legal Department   
3800 NE 1st Ave
Suite 600
Miami, FL 33137   
United States