Great Clips Customer Data Privacy Notice
Last Updated: December 31, 2019
Effective: January 1, 2020
We urge you to read this Privacy Notice so that you understand our commitment to you and your privacy and how you can participate in that commitment.
At Great Clips, Inc. (“Great Clips” or “we” or “our”), the privacy of our customers is very important to us. We collect and use personal information about our customers (“you” or “your”) at Great Clips® salons, which are independently owned and operated franchised businesses, and at www.greatclips.com (including related sites at https://jobs.greatclips.com/, and https://greatclipsfranchise.com) (collectively, the “Site”) to create and maintain a relationship that allows us to provide quality services and products.
We also collect and use personal information submitted or made available through your use of our Great Clips® mobile or tablet device application (the “App”). This Privacy Notice is intended to inform you about how the personal information you submit in a salon or through this Site or our App will be handled and protected.
We reserve the right to modify this Privacy Notice from time to time and will mark new versions with a corresponding effective date. We recommend customers visit the Site to review any changes in our practices. By using this Site, our App, using our services, and visiting or communicating with us through our salons, you agree to the terms of this Privacy Notice.
What Information is Collected?
Information is voluntarily provided by the customer through any of the methods listed above . Customer Information may also be collected through your participation in a sweepstakes or other give-away sponsored by us, to locate a salon, to provide “check-in” information electronically through the Salon Locator section of the Site or App, to take advantage of Site or App functionality, or to otherwise participate in activities or services generated on the Site or in the App. Information may also be collected from customers when they download our App, respond to push notifications that were enabled by the customer, and use our "check in" function to add their name to the waitlist at a local salon. Such information may include a customer's geolocation—to help the customer locate the nearest salon—and the customer's first and last name and phone number to make an appointment (although such information is not required to access the services in the salon). Great Clips, Inc. stores the information it collects on servers located in the United States.
The Site may also collect information about technology interface preferences (such as the type of browser or device used or the files requested) to improve the Site and better meet your needs. Great Clips works with third-party businesses to ensure that such information is complete and accurate.
Our Site and App are not designed for children, and we do not collect information online from any person we know is under the age of 13.
The information we may collect includes, but may not be limited to:
- Descriptions of how you like your hair cut, descriptions of your hair or other details relevant to your visit that are captured for use at a future visit (known as Clip Notes®);
- A customer’s identity or contact information, such as their name, address, phone number, e-mail address;
- A customer’s transaction history with Great Clips for products or services they have obtained from a salon;
- Computer data or files, often called “cookies,” which may be sent by a customer’s web browser and stored on an individual computer to allow our server to “recognize” the customer through the navigation of the Site;
- A customer’s IP address to measure our website traffic and to help provide more personalized salon information and ensure a high level of site performance;
- Information regarding the customer’s unique application cookie to distinguish one application installation from another;
- A customer’s mobile phone number to participate in promotional activities through the Site or at a local salon;
- Information regarding the type of device used by customers to access our App, such as whether it is through an iPhone®, Android®, or online browser.
Franchisees may be collecting additional details and information not covered under this Privacy Notice, but as may be separately disclosed by the independently owned and operated salon. This could include things like video captured by security cameras or other marketing tools not currently in use by Great Clips, Inc.
We may also collect information that is related to you but that does not personally identify you (“Non-personal Information”). Non-personal Information also includes information that could personally identify you in its original form but that we have modified (for instance, by aggregating, anonymizing, or de-identifying such information) in order to remove or hide any personal information.
What is the Talent Community as used at jobs.greatclips.com?
Individuals who submit their information on the Great Clips Career Site (http://jobs.greatclips.com) are joining a community of individuals (the “Talent Community”) interested in receiving job notifications, event alerts, general career-related information, industry news, and other related content. This community is also known as “the Stylisthood.” Great Clips, Inc. and its franchisees may also enter information into the Talent Community database from individuals who have expressed interest in Great Clips and/or the Great Clips Talent Community that is collected upon submission by the individual outside the Career Site at another event.
How is Information Used?
We collect basic information about our customers in order to provide services to them, to conduct business or customer service, for legal compliance, for marketing initiatives, and for research and analytical purposes, including but not limited to:
- Providing quality, efficient haircuts with personalized service;
- Tracking information about our customers’ last visit, such as technical information related to a particular haircut or products purchased;
- Tracking customers’ Site usage and App preferences to offer a better customer experience, monitor online and App traffic, troubleshoot issues with the Site or App, and block abusive users of the Site or other security measures;
- Computer data or files, often called “cookies,” which may be sent by a customer’s web browser and stored on an individual computer to allow our server to “recognize” the individual through the navigation of the Site;
- Learning about who our customers are, how often they visit us, and their expectations pertaining to their services so we can continue to meet their needs;
- Sending or initiating direct marketing offers or coupons;
- Surveys about your experience on our Site;
- Employment history, education or licensing information (for those accessing jobs.greatclips.com);
- Reaching out to those who have submitted an interest form for jobs at Great Clips or otherwise providing tailored employment opportunity information, determining your qualifications and making hiring decisions; and
- Contacting customers when they have left a personal item in the salon or to follow-up to customer feedback.
How is Information Shared and Protected?
In order to provide the services and improve the Site or the App, we may engage the services of third-party businesses. In the process of supplying services, these third-party businesses may need access to or receipt of certain information to perform the services we have requested, including without limitation, data research and analytics, initiating direct marketing programs, data tracking, maintaining or developing the Site or App, ensuring that contact information is complete and accurate, or other contracted promotional opportunities provided to the customer. Great Clips may share this information with any subsidiaries, licensees, affiliates, assigns, successors, or other respective owners. Great Clips may also share your personal information in connection with law enforcement requests or in response to subpoenas, court orders, or other legal process to establish or exercise our legal rights or defend against legal claims.
The security of your information is of the utmost importance to Great Clips. Great Clips uses appropriate administrative, technical, personnel, and physical safeguards to protect the security of your personal information from unauthorized disclosure. We also make all reasonable attempts to ensure that only necessary people and third parties have access to personal information in order to safeguard your personal information against loss, theft, and unauthorized use or modification.
Retention and Deletion of Information.
Great Clips retains information for as long as is reasonably necessary to provide services to you or otherwise has an articulable business need to retain it. Great Clips will also retain your information as reasonably necessary to comply with our legal obligations. California residents may at any time request that we correct or delete their Personal Information (defined below) by contacting us as outlined below.
Additional Privacy Notice Provision for California residents:
Great Clips, Inc. (“we,” “us,” or “our”) includes this provision specific to California residents and households in accordance with the notice requirements under the California Consumer Privacy Act of 2018, as amended (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this California Privacy Notice.
This California Privacy Notice section applies only to information collected through the Site and the App, and information collected through other channels, such as over the phone or in person.
Definitions Specific to this Policy
The CCPA includes definitions for terms specific to this California Privacy Notice provision and to California residents that do not apply to the rest of Great Clips, Inc.’s Privacy Notice, including the following terms:
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include publicly available information obtained from government records; de-identified or aggregated consumer information that cannot be reconstructed to identify you; any information covered under the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act, activities covered by the Fair Credit Reporting Act, or protected health information as defined under the Health Insurance Portability and Accountability Act.
“Sale” or “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.
“Service Provider” means a sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its shareholders or other owners, that processes information on behalf of a business and to which the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.
“Third Party” means a person or entity who is not a business that collects Personal Information from consumers as defined in the CCPA, and to whom the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.
The Personal Information We Collect and Disclose
The chart below shows the categories of Personal Information we collect or “may collect”; examples of the type of Personal Information in each category; types of sources from which each category of Personal Information is collected; the business purpose(s) for which that category of Personal Information is collected; and types of third parties with whom that category of Personal Information is shared. This information covers the past 12 months.
|Categories of Personal Information||Examples:||Types of Sources from which this Category of Personal Information Is Collected||Business Purpose(s) for Collection||Types of Third Parties with Whom Sold and/or Disclosed|
|Unique identifiers||Name, address, telephone number, email, account name, online identifier, IP address||Consumer, marketing vendors, internal point of sale, Site and App||Marketing, providing the services (Online Check-In), customer service||Service Providers, marketing vendors; internal use|
|Government ID number (for job applicants and employees only)||Social security number, passport number, driver’s license or state identification card number||Consumer||Job hiring decisions||HR vendors, third party identity verification services, government authorities|
|Physical description||Physical characteristics or description||Stylists||Provide the services to the customer (e.g., Clip Notes)||Service Providers|
|Financial information||Bank account number, credit card number, debit card number, or any other financial information (encrypted)||Consumer (or employee, if applicable)||Process payment transactions; (process payroll)||Payment processor; (internal HR system, if applicable); not sold|
|Health/medical Information (for potential employees and employees only)||Medical information, or health insurance information||Consumer||Employee file for emergency purposes||Employer HR system; not sold|
|Insurance information (for potential employees and employees only)||Insurance policy number, health insurance information||Consumer; employer||Documenting information in the event of an emergency||Consumer; Government authorities; not otherwise sold|
|Protected class data||Characteristics of protected classifications under California or federal law, including: age (40 years or older), marital status, sex, medical condition, disability||Consumer||HR and employment matters||Internal legal compliance; Not sold|
|Purchase history||Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||POS||Providing customer service; marketing processing returns and payment issues||Marketing vendors|
|Internet activity||Internet or other electronic network activity information, including, but not limited to, browsing history, search history, key strokes, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement, cookies||Site and App; Service Providers||Providing goods/services marketing||Internal analytics and account verification; internet hosting providers; marketing vendors|
|Geolocation data||Geolocation data||App (user-entered)||Showing nearest salons; marketing||Marketing vendors; internal analytics|
|Audio, visual, olfactory information||Some visual information as may be captured in Clip Notes (e.g., physical features, pictures of customers with haircuts)||Consumer; stylists||Providing the in-salon services||Not sold|
|Employment information (applicable to potential employees and employees)||Professional or employment-related information and information required to be collected during the hiring process, as applicable (e.g., SSN, DL number, passport number)||Consumer; educational institutions; certification authorities||Information about what you do, where you work and your certifications||Internal HR systems; identity verification vendors; not sold to third parties|
|Education information (for potential employees and employees only)||Personally identifiable education information that is not publicly available||Consumer; school/educational institution (with permission)||Verifying education history for employment purposes||Internal HR systems; identity verification vendors; franchisee employers (if applicable); not sold|
|Inferences||Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, behavior, attitudes||Consumer; stylists; cookies; Clip Notes upon in-salon visits||Analytics; providing goods / services||Marketing vendors; franchisees|
We will not collect a category of Personal Information not listed above, or use any Personal Information collected in any of the above categories for a business purpose not listed above, without first providing you with notice.
You have the right to request certain information regarding the Personal Information we have collected about you in the preceding 12 months. You may make such a request up to twice in a 12-month span. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if this is the case.
- If you would like to opt out of the sale of your Personal Information;
- If you would like to request (1) the categories of Personal Information collected about you; (2) the categories of sources providing that Personal Information; (3) the categories of third parties with whom we have shared that Personal Information; and (4) the business purpose for collecting that Personal Information;
- If you would like to request the specific pieces of Personal Information we collected about you;
- If you would like to request (1) the categories of Personal Information collected about you; (2) the categories of Personal Information sold; (3) the categories of third parties to whom the information was sold; and (4) the categories of Personal Information that were disclosed for a business purpose;
- If you would like to request (1) access to specific pieces of Personal Information collected about you; or (2) deletion of your Personal Information;
Click here or call 1-800-GREATCLIPS (1-800-473-2825), option 3. The link will take you to an interactive webform that you can complete and submit to make the request that we will then verify; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request, and the level of verification will depend on the request being submitted. You may also obtain a written form (with a pre-paid envelope) at a salon location in CA.
More on opt-out requests: You have the right to request that we do not sell Personal Information that we have collected. If you exercise that right, please note that pursuant to the CCPA we may have to subsequently inform you that you need to opt-in if the sale of your Personal Information is required to complete a transaction you have initiated. If opting-in is required, we will provide you with the necessary instructions.
If you opt-out of the sale of your Personal Information, we will wait at least 12 months before asking you if we may sell your Personal Information.
You have the right to opt-in to the sale of your Personal Information after you have opted out through the same process outlined above. Opting-in is a two-step process in which you will first clearly request to opt-in, and then separately confirm that choice.
More on deletion requests: You have the right to request that we delete certain Personal Information that we have collected. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if this is the case.
The verification process varies slightly depending on what right you are exercising. However, you can exercise your rights as follows:
- You are not required to create an account to exercise your rights;
- By accessing privacy.greatclips.com (or calling the 1-800 number or mailing , in which case such request will be inputted on your behalf) you can Make a Request;
- You will be asked to indicate your residency;
- You must then indicate which request you wish to exercise based upon the list of options presented;
- To request to opt-out of the sale of your Personal Information, provide your first name, last name and email, then you must click the verification link in your email for your request to proceed.
- To request deletion of your Personal Information, this same process is required, then you will be required to further confirm you wish for the information to be deleted before additional validation may be requested in the form of additional questions;
- To request access to your specific Personal Information, the same process to opt-out is required, but then additional validation will be requested in the form of additional questions based upon the Personal Information we have about you to validate your identity before the request is completed;
- Additional steps may be required as the CCPA regulations are finalized or the California Attorney General issues further guidance on the verification process.
- You may create a free account on the platform for easier access to make additional requests or verify the status of any pending request.
IF YOU DO NOT PROVIDE AN EMAIL ADDRESS DURING THIS PROCESS, YOU MAY NOT BE ABLE TO COMPLETE THE VERIFICATION PROCESS OR OTHERWISE RECEIVE RESPONSES DETAILING THE STATUS OF YOUR REQUEST. IN THIS INSTANCE, YOU WOULD HAVE TO CALL 1-800-GREATCLIPS OR SUBMIT A WRITTEN FORM (OBTAINED FROM A SALON) IN ORDER TO CHECK ON THE STATUS OF YOUR ORIGINAL REQUEST.
Please note that we may be unable to identify you, including, but not limited to the following reasons: (1) you have provided different spellings of your name or you operated under a different name at any point in your interactions with Great Clips, (2) you moved or changed your phone number without having your information updated, (3) you don’t respond to the verification email (please be sure to check your junk or spam folders), or (4) we have reason to suspect the request being made is with mal-intent or otherwise fraudulent in nature. If you have provided multiple names, phone numbers or addresses, you must submit separate requests for each piece of information for us to properly identify you and/or delete your Personal Information.
Financial Incentives and Non-Discrimination
We will not discriminate against you if you exercise any of the rights provided by the CCPA set forth in this Privacy Notice. Please note that a legitimate denial of a request for information, deletion, or to opt-out is not discriminatory, nor is charging a fee for excessive or repetitive consumer requests as permitted by the CCPA.
However, if we decide to offer a loyalty program or change our current marketing program, we may offer financial incentives to consumers who allow us to retain and disclose their Personal Information. These incentives may include payments to consumers, a lower price for goods or services, and/or a higher level of goods or services. If enacted, you may withdraw from the incentive at any time. If you have previously opted-in to the incentive below and wish to opt-out, click here.
Our incentive is permissible under the CCPA because the information you provide is valuable for us to offer the best goods and services, a great customer experience, and to otherwise improve our business, and for any other reason articulated at the time the incentive is offered. This section will be updated in the future if such incentive is offered, with the specifics of the incentive, the estimated value of incentive and how we arrived at the dollar value.
You may designate an authorized agent to exercise your rights under the CCPA on your behalf. Pursuant to the CCPA:
- Only a business entity or natural person registered with the California Secretary of State may act as an authorized agent.
- You must provide the authorized agent written permission to exercise your rights under the CCPA on your behalf.
- We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof, as permitted by the CCPA.
- Even if you use an authorized agent to exercise your rights under the CCPA on your behalf, pursuant to the CCPA we may still require that you verify your own identity directly to us. This provision does not apply if you have provided with a power of attorney under California Probate Code sections 4000 to 4465.
Personal Information of Minors
We do not sell the Personal Information of minors who are under 13 years old unless a parent or guardian of that minor affirmatively authorizes the sale of that Personal Information through one of the following methods:
- The parent or guardian used a credit card, debit card, or other online payment system that provides a discrete transaction to the primary account holder in in connection with any monetary transaction (such as upon the completion of a salon service).
- The parent or guardian is provided a consent form to be signed under penalty of perjury and returned to us.
- The parent or guardian calls our toll-free telephone number to provide verifiable consent.
As part of that verification process, the parent or guardian may be informed that he or she may opt out on behalf of the minor at a later date and what the process is for doing so.
Personal Information Metrics (to be provided and updated once information becomes available after January 1, 2020).
|Type of request||Number received||Number complied with (in whole or in part)||Number Denied||Median number of days to provide a substantive response|
|Request to Know|
|Request to Delete|
|Request to Opt-Out|
If you would like additional information regarding privacy actions taken specific to California, please call us at 1-800-GREATCLIPS or email us at firstname.lastname@example.org.
Additional California Privacy Rights
California Civil Code Section § 1798.83 permits users of our web site that are California residents to request certain information regarding our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to email@example.com with the subject “Shine the Light Request.”
Does This Privacy Notice Apply to Third-Party Websites Accessible Through GreatClips.com?
The information practices of third-party websites linked to our Site are not covered by this Privacy Notice. Other sites accessible through our Site have their own privacy notices and data collection, use, and disclosure practices. We are not responsible for the policies or practices of third parties. These other websites may send their own cookies to users, collect data, or solicit personal information. We cannot control this collection of information. You should consult each website’s privacy notice or contact these websites directly if you have any questions about use of the information that they collect.
By providing information to Great Clips salons or browsing or providing information on the Site or through the App, customers are providing their consent for Great Clips to use their personal information as outlined in this Privacy Notice.
Great Clips will not use or share personal information provided to us in ways incompatible with those described above, and we do not sell, for monetary consideration, your personal information to anyone. To the extent that applicable law requires express consent, express written consent, or “opt-in” for the collection and use of certain types of personal information, Great Clips will maintain processes and procedures to ensure such information is collected with express consent. Each digital communication customers receive from Great Clips unrelated to services you have specifically requested will give customers instructions on opting out or unsubscribing.
How Can Customers Limit Information Collected or Withdraw Consent?
While we work hard to ensure we use and disclose our customers’ personal information only for the purposes identified in this Privacy Notice, customers can choose not to provide personal information or limit the personal information obtained by us. Please note that by refusing to provide required information may result in our inability to provide certain customer service requests, provide the highest quality service possible, or otherwise comply with your specific request.
If you have questions or concerns about Great Clips’ policies and practices for handling your personal information you may use the following methods to contact Great Clips:
- Access our website at www.greatclips.com/, and select “Contact Us” found in the footer to send an e-mail.
- Call our customer service at 1-800-GREATCLIPS (1-800-473-2825).
For additional information pertaining to our privacy practices, please contact our privacy team at firstname.lastname@example.org.
© 2020 Great Clips, Inc.