This Privacy Policy (or “Policy”) tells you how JMB Glamsquad, LLC (“GLAMSQUAD”, “we”, “us” and “our”) collects, uses, shares, secures, and eventually deletes information collected from and about visitors to Website.

By visiting and using our Website and Apps You are agreeing to the terms of this Policy and consent to the collection, use, and sharing of your Personal Information as outlined below. If You do not agree, then please exit our Website and close Your browser and/or uninstall our application.

Scope

This Policy applies to our Customers, Users, and Beauty Professionals, as defined below, and covers our data collection activities on our Website and Apps.

Definitions

“Customer” means a natural person that uses our Website and Apps to book a Beauty Professional for beauty services, or has joined our Membership Program.

“Personal Information” means any information relating to an identified or identifiable individual that is collected from our Customers, Beauty Professionals, and Users via our Website and Apps. Personal Information may include: full name, physical address, email address, IP address, or other identifier such as from a Cookie.

Personal Information does not include any aggregate or anonymized data that may have been created from Personal Information but can no longer be used to identify, relate to or could reasonably be linked to a Customer, Beauty Professional or User.

“Sensitive Personal Information” means any information collected from our Customers, Beauty Professionals, and Users that reveals a racial or ethnic origin, religious belief, philosophical belief, or trade union membership. It also may include a natural person’s genetic and biometric data, financial information, and data concerning their health, sex life or sexual orientation.

“Services” means the services provided via our Website to facilitate and support the booking and completion of a beauty appointment with Beauty Professionals.

“Beauty Professional(s)” means an independent contractor in the business of providing beauty services who uses our Services to provide beauty services directly to customers, and includes hair stylists, makeup artists, and nail technicians.

“User” means a natural person that visits and interacts with our website.

“You” or “Your” means a Customer, Beauty Professional, or User.

“Website and Apps” means https://glamsquad.com/ and the GLAMSQUAD mobile applications.

GLAMSQUAD's Information Collection Practices Overview

GLAMSQUAD allows our Customers the ability to book the beauty services that they need at the time and location that they want. We also allow Beauty Professionals to have the flexibility to connect with Customers and provide their services directly to Customers.

In order to provide our Services, we need to collect certain information from You. It is our policy to only obtain the Personal Information that is absolutely necessary to provide our Services to You and we only share that data with third parties that have a need for it to support the provision of the Services, such as with Beauty Professionals.

As we strive to provide You with the best service and experience, certain information may also be used to maintain and improve our customer service to You; be used to create and develop new services, offerings, and events; and otherwise support the provision of our Services to Customers and Beauty Professionals. We have outlined all of the different ways that we collect, share, and use Your information in this Policy.

Information That We Collect From You When You Visit Our Website

We collect certain Personal Information from You in order to operate our Website and Apps effectively and provide You with the best experiences when You visit and use them.

Information You Provide to Us

When You use our Services or create an account with us, we may collect Personal Information from You, such as Your first and last name, e-mail address, home address, date of birth or age range, and telephone number. Depending on the type of beauty service You are booking, we may also collect certain of Your Sensitive Personal Information, such as Your gender, facial attributes (e.g., hair color, eye color, skin type, skin tone, skin shade, etc., which may allow us to infer Your race and ethnic identity), and possibly information about Your health. We may also collect Your geolocation in specific circumstances, such as when You book our Services, to determine whether we are able to provide our Services to Your region.

When You interact with our Website and Apps, we may collect additional Personal Information as needed, such as information that You include in posted messages, and communications with the Beauty Professional that You booked. On the Services or on an SNS where we have a page or presence (collectively “SNS Pages”), the information contained in Your posting may be republished on our Website and other users may be able to see them.

If You are a Beauty Professional, we collect additional information about You to optimize functionality of our Website and Apps. This information includes Your Sensitive Personal Information (such as Your geolocation when moving from appointment to appointment and Your financial information to allow for payment via our third-party payment processor, Stripe), and other Personal Information such as reviews from Customers about Your work. This and any other information we collect from You shall not be used to control the beauty services You provide to Customers.

Information Collected via Technology Tools

We also may use various technologies and methods to collect information directly from You or from Your computer or device and about Your activities on our Website and Apps.

Information Collected Automatically

We may automatically collect information from You, including Your browser type, operating system, Internet Protocol (IP) address, domain name, and/or a date/time stamp for Your visit, the content of any undeleted cookies that Your browser previously accepted from us, referring or exit website address, internet service provider, date/time stamp, operating system, locale and language preferences, and system configuration information.

We may use third-party analytics services to also collect such information and additional information about Your use of and interactions with our Website and Apps as well. Our third-party analytics providers include: Google Analytics, Google Adsense, Google Tag Manager, and Mixpanel.

To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google at https://tools.google.com/dlpage/gaoptout?hl=en. To learn more about privacy and Google Analytics, please see: https://policies.google.com/technologies/partner-sites.

Mixpanel collects and analyzes Customers’ and Users’ movements while visiting the Website and Apps, including the links You click. You can review Mixpanel’s privacy policy here and may opt out here.

We may also collect information from You automatically through any site or web application that we may develop and run on a third-party social network such as Facebook. This could also include any site or application that we specifically design for use on a cell phone or other mobile device, such as a mobile-enabled site (i.e., WAP site) or mobile application (e.g., iPad/iPhone or Android app).

Cookies

We also use cookies and URL information to gather information regarding the date and time of Your visit and the information for which You searched and which You viewed. Through the use of a cookie, we also may automatically collect information about Your online activity on our Website, such as the web pages You visit, the links You click, and the searches You conduct on our Website. Most browsers automatically accept cookies, but You can usually modify your browser setting to decline cookies.

“Cookies” are small pieces of information that a website sends to Your computer’s hard drive while You are viewing a web site. We may use both session cookies (which expire once You close your web browser) and persistent cookies (which stay on Your computer until You delete them) to provide You with a more personal and interactive experience on our Website. Persistent cookies can be removed by following Internet browser help file directions.

We use cookies to personalize content and ads, to provide social media features and to analyze our traffic. We also share information about Your use of our Website with our social media, advertising and analytics partners, who may combine it with other information that you've provided to them or that they’ve collected from your use of their services.

When You first visit our Website, we provide You with a choice to either accept or deny certain cookies. If You choose to decline cookies, please note that some of the features and services of our Website may not function as well as intended. Even if You choose to accept cookies, you are always free to change Your mind and revoke that consent.

Other technologies

We may use standard Internet technology, such as web beacons, pixels, and other similar technologies, to track Your use of our Website. We also may include web beacons in promotional e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer to Customers and Users, to deliver targeted advertisements, and to measure the overall effectiveness of our online advertising, content, programming, or other activities. Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies, which are stored on Your device, web beacons are embedded invisibly on the web pages (or in emails) and are about the size of the period at the end of this sentence. Web beacons may be used to deliver or communicate with cookies, to count visitors to certain pages, and to understand usage patterns. We also may receive an anonymous identification number if You come to our Website from an online advertisement displayed on a third-party website.

Information Collected from You at Your Appointment

We may need to collect additional information from You during Your appointment with a Beauty Professional. Specifically, we may need to collect additional Sensitive Personal Information, such as information about a health condition or accommodation that the Beauty Professional must be aware of, and information about Your race and ethnic identity.

Beauty Professionals are independent contractors and they may ask to collect additional information that is not going to us. Specifically, Your Beauty Professional may ask You to allow them to take a photograph or video of Your beauty treatment or the results of the same. You do not have to consent to any such further collection, and we are not responsible for such information that is collected by Beauty Professionals, and You should confirm how they will use such information before You consent to the collection of the same.

Information Collected from You Over via Phone and E-Mail

We utilize third-party providers to facilitate our communications with You. Specifically, we utilize Klaviyo for our marketing communications, Twilio Inc. (“Twilio”) for appointment-related communications, and Vonage Holdings Corp. (“Vonage”) for our internal communications. If You sign up to receive text messages from us, these providers will receive certain information about You, including Your mobile phone number. We do not share mobile information with any other third parties/affiliates for marketing or promotional purposes. You can review each provider’s privacy policy here:

• Klaviyo: https://www.klaviyo.com/legal/privacy/privacy-notice
• Twilio: https://www.twilio.com/en-us/legal/privacy
• Vonage: https://www.vonage.com/legal/privacy-policy/

Additionally, we may collect information from You through one of our inbound text messaging programs. For example, periodically we may allow customers to send us inbound text messages using a short code that we create and advertise in connection with a special offer or promotion. These programs might be advertised on our Website and Apps. In addition to the message itself, we may also collect Your geolocation information as well and use that information to send You personalized marketing messages. As noted above, we do not share Your mobile telephone number with any third parties to use for their own promotional/marketing purposes. We may also keep a copy of Your text messages for our business purposes and as needed for any follow-ups You may have about the issue You contacted us about. If You do not consent to the same, please contact us via email at contact support@glamsquad.com or via phone at 844-695-4526 instead. Additionally, if You provide us with Your picture as part of the text communication, we will review the picture as discussed and it may be kept as part of the transcript of Your live chat as noted above, but we do not scan any pictures for Your facial geometry or use Your picture(s) for any other purpose besides to address the issue as to why You sent it to us.

If You email us, we will collect Your contact information and Your email address in order to respond to Your email. We may need to collect additional information depending on the reason why You emailed us as well, such as information about Your appointment, and Your home address.

Information Collected about or from You from Social Media

Customer Generated Content

We may collect Personal Information from content that You create and then share with us (and perhaps others) through our Facebook fan pages, TikTok, or other related applications. Such Personal Information may include photos, videos, personal stories, or other similar media or content. This information may be considered or reveal Sensitive Personal Information too, as it could reveal Your race, gender, and depending on the type of content could also potentially reveal sexual orientation, political opinion, and health information. Generally, such customer-generated content is collected in connection with any contests and promotions we are running, and also from the third-party website’s community features, customer engagement information, and other social networking information.

Directly from Your Social Media Account

If You have consented on a third-party social media site to sharing Your Personal Information with other third-parties, then we may collect Your Personal Information that is part of Your profile or that You post publicly. Examples may include Your basic account information (e.g., name, email address, profile picture, gender, birthday, current city, user ID, list of friends, etc.) and any other additional information or activities that You permit the third party social network to share with application developers or that You post publicly on a GLAMSQUAD social networking page. For example, we may receive Your social network information (or parts of it) when You download or interact with a GLAMSQUAD Application on a social networking site (such as Facebook) or use a third party social networking feature that is integrated within our Website (such as Facebook Connect). This is Personal Information that is shared with us, and You should consult the third-party social media site that You use for more information on how they collect Your Personal Information and how to opt out of such collection and otherwise exercise Your rights.

Information Collected about You from Third Parties

Occasionally, we may obtain information about You from third parties, such as a data aggregator or vendor to provide us with additional information about our existing Customers (this is known as “data appending”), which may include information from Your GLAMSQUAD account profile or Your postings on a third-party social network.

We may also receive information about You from Rakuten Advertising (“Rakuten”), which may collect Personal Information from You when You use their services and when You interact with their digital property. This information may include Your address, digital identifiers, information about Your web browsing and app usage, and how You interact with Rakuten’s properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how You engage with websites or ads and other commercial purposes. For more information about Rakuten’s data collection and privacy practices, please review their privacy policy here: https://rakutenadvertising.com/legal-notices/services-privacy-policy/. For information on how to exercise Your privacy rights with Rakuten, please click here

Use of Your Personal Information

We collect Your Personal Information and Sensitive Personal Information for various reasons, which are described below:

To Service Our Website and Apps

We use information collected to ensure that our Website and Apps are working as intended and for analytics purposes, to understand how our Website and Apps are operating and learn how they can be improved. We also use this information as needed for auditing purposes.

To Fulfill Your Appointment and Facilitate the Beauty Professionals Providing the Beauty Services to You

We use information collected to facilitate connection to a Beauty Professional, facilitate the beauty appointment and to follow up with You about Your satisfaction with the same.

To Maintain Your Account

We may use information collected to maintain Your accounts with us, including administering any programs associated with such accounts.

For Our Marketing Purposes

If You have filled out a contact form with us, signed up to receive our text messages, or have otherwise signed up to receive our direct communications, we may use this information to send You marketing communications, such as email communications, mobile messages (including text and/or push notifications), and postal mailings. These communications may inform You about new service offerings, special discounts and coupons, beauty tips, and other news and special offers. On occasion, these communications may also contain information or offers about third party products. In some instances (such as for mobile messages), we may use technical information or precise geo-location information obtained from Your mobile device to send You messages directly to Your mobile device, including offers and coupons based on Your location.

To Evaluate and Improve our Customer Service

We may use this information to ensure we are providing the highest level of customer service, and to identify any potential gaps or potential improvements to the same. Customer service may be provided through various forms of communication, such as email correspondence and call center support.

In Order to Respond from Requests from You

If You have requested further information or in any other way requested that we contact You, we will use Your Personal Information to respond to such a request.

To Provide a Personalized and Convenient Website Experience for You

We may use information collected to personalize Your experience and save You time when You visit our Website. For example, we might remember Your login ID or username so You can quickly login the next time You visit our Website.

To Facilitate and Enable Your Interactions with Third-party Social Media Providers

We may use information collected to support and run contests, to allow You to share content (such as beauty tips, articles, stories, etc.), and to allow You to sign up for certain of our social media accounts, or for other stated purposes as disclosed via the relevant advertisement or promotion.

For Our Other General Purposes

We may use information collected for other general business purposes, such as to maintain the day-to-day operation and security of our Website and Apps, and to conduct internal marketing and demographic studies.

For Our Legal Purposes

We also collect information in order to comply with certain legal rules and regulations that we are subject to.

Storing Your Personal Information.

We only store and maintain your Personal Information for as long as is necessary to fulfill the purpose for which it was collected. For example, if You are one of our valued Customers and have created an account with us, we store Your Personal Information as long as Your account remains active, and then delete it when You delete the account, with the exception of any information that we are legally required to maintain longer.. With regards to Your Personal Information collected for our analytics purposes and used to help maintain and improve our Services, we only store and maintain that information until it is aggregated and used to create a new anonymous data set that no longer contains Your Personal Information, and then delete the underlying Personal Information once that new data set has been created. When we no longer have a legal need, or You close or delete Your account with us, or otherwise ask us to delete Your account, we will do so securely in accordance with our document retention policy. If You are a Beauty Professional, we store Your Personal Information for the duration of Your affiliation with us, with the exception of any information that we are legally required to maintain longer

How We Share Your Personal Information

While we do not sell Your Personal Information to third parties for monetary gain, GLAMSQUAD discloses certain categories of Your Personal Information to show You targeted ads on third-party websites and to expand the reach and effectiveness of our own marketing campaigns. These activities may be considered a sale under certain state privacy laws. You may opt out of marketing-related communications by following the unsubscribe or opt-out instructions contained in the marketing communications we send You. For additional opt out assistance, You may email us at support@glamsquad.com.

Who We Share Your Personal Information With

Generally, we share your Personal Information as necessary to provide our Services to You, including sharing information with certain third parties, such as service providers. We also may share Your Personal Information when required to by law; to protect Your rights and safety, and with Your consent.

Specifically, we may share Your Personal Information with third parties, including:

Authorized Beauty Professionals

We need to share Your Personal Information with Beauty Professionals in order to facilitate Your appointment with them.

Authorized Service Providers

We may share Your Personal Information with our authorized service providers that perform certain services on our behalf. These services may include relationship management software; website hosting; evaluators, contractors and auditors; email marketing providers; customer service providers; providers that perform business and operations analysis for us; and providers that support and maintain our Website, including providing analytics services for us.

Payment Processors

We need to share your Personal Information and your Sensitive Personal Information with our third-party payment processor, Stripe, in order to complete Your purchases, and, if You are a Beauty Professional, to complete Your payment. You may also be able to store Your payment information with Stripe via Your account with us. We do not store any of Your financial information directly and any such storage or remembering of the same will be facilitated by our third-party payment processor.

For Corporate Reasons

We may also share Your Personal Information as part of a sale, merger, or change in control or ownership of GLAMSQUAD, or in the unlikely event of bankruptcy, or in preparation for any of these events. If such an event should happen, the new entity would have the right to continue to use Your information, but only in the manner that is set out in this Policy, unless You otherwise agree.

Compliance and Protection

Regardless of any choices you make regarding your Personal Information (as described below), we may disclose Personal Information if we believe in good faith that such disclosure is necessary (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on us; (iii) to protect or defend our rights or property or that of other users of the Services; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Policy, or our Terms of Use.

To Prevent Fraud or Illegal Conduct

We may have to share your Personal Information in situations where we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property, or safety of our company, our consumers, our employees, or others; or to enforce our Terms of Use or other agreements or policies.

Our Advertising Partners

We may also allow third parties through an advertising network to target custom content and ads to You on our Website, and other websites. The information provided to these service providers is limited to only that which we deem appropriate for these service providers to carry out their functions, such as offering You certain promotions or customizing certain advertisements for You, and enable us to market to You.

For a Legal Reason

We may have to share Your Personal Information in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.

With Your Consent

To other parties that You provide consent to share Your information with or that You have requested that we share Your information with.

Third Party Websites

When You click on a link to any other website or location, You will leave our Website and go to another site and another entity may collect Personal Information or Anonymous Data from You. We have no control over, do not review or endorse, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Policy do not apply to these outside websites or content, or to any collection of data after You click on links to such outside websites. You should check the applicable privacy notice and/or policy of the third-party website or application to understand how it collects and manages any information they collect from You.

Security of Your Personal Information.

We are committed to protecting the security of Your Personal Information, and maintain a comprehensive Information Security program that employs commercially available physical and IT securitization tools, including but not limited to:

• Commercially available and sufficient firewalls
• Segmented Data Storage
• Encryption
• Multi-factor authentication
• Policies providing for at least privileged access to data across our organization

We also ask that You do your part to keep Your account information safe and secure, by asking that You create a sufficiently complex password for Your account and not share it with third parties, as outlined in our Terms of Use. If You have any questions about the cybersecurity for our Services, You can send an email to info@glamsquad.com.

Unfortunately, however, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and there is no way to completely eliminate the risk of a data security incident. Therefore, while we use reasonable efforts to protect Your Personal Information, we cannot guarantee its absolute security. If we do suffer a security incident that affects any of Your Personal Information, we will report the same to you as per applicable data breach notification laws.

Do Not Track ("DNT") Settings

DNT is a setting on some web browsers or mobile devices that can be turned on to instruct websites to disable tracking of your web browsing activities. DNT is not currently widely adopted and does not have clear standards or guidelines as to how websites are to interpret it. Additionally, its signals can affect the functioning of certain websites. As such, GLAMSQUAD does not generally respond to these signals.

Third-Party Tracking on Our Website

Third parties may be using cookies or other technologies to collect your Personal Information as You navigate the internet, including from our Website. You may decline these third-party cookies by changing Your browser settings.

Children’s Personal Information

Our Website and Apps are not made for, marketed to, or directed at children under the age of 16 years of age. If requested by a consenting parent, Beauty Professionals will perform beauty services on children, but only if the parent is present for such services.

Nevada Privacy Rights

We do not sell, rent, or otherwise share Your data to any third party in exchange for monetary or other valuable consideration under any circumstances unless You specifically consent to such disclosure. Pursuant to Section 603A of the Nevada Revised Statutes, residents of Nevada may, at any time, submit a request to an operator of a website in Nevada directing the operator not to make any sale of any personal information the operator has collected or will collect about the consumer. If You are a Nevada resident and want to opt-out of the sale of any personal information, please submit an email request to info@glamsquad.com. In your request, please specify that you want to “Opt-Out of Sale of Personal Information in Nevada.” Please allow 60 days for a response.

California Shine the Light Law

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of Personal Information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. If You are a California resident and want a copy of this notice, please submit an email request to info@glamsquad.com. In your request, please specify that You want “Your California Privacy Rights Notice.” Please allow 30 days for a response.

Contact Information

GLAMSQUAD welcomes your comments or questions regarding this Policy. Please e-mail us at privacy@glamsquad.com or contact us at the following address or phone number:

JMB Glamsquad LLC
169 Madison Avenue
Suite 2087
New York, NY 10016
844-695-4526

Changes to This Policy

Any changes to the Policy will be posted directly on our Website and reflected with a new Last Revised date at the top of this Policy. We encourage You to review the Policy each time You visit our Website to see if it has been updated since Your last visit.