PRIVACY POLICY

PLEASE READ THIS PRIVACY POLICY BEFORE USING THIS SITE OR MANNERED MANES SERVICES

Mannered Manes, Inc. (the “Owner” or “Mannered Manes”) is a Delaware corporation with principal offices at 5303 S. Mason Rd.  Katy, TX 77450 and may be contacted by email at info@manneredmanes.io.  Mannered Manes owns and operates mobile applications on Apple and Google platforms (the “Apps”) as well as a website: www.manneredmanes.io (the “Website”).

This policy is effective as of:  Sept 15, 2022. 

What this policy covers

This Privacy Policy explains how Mannered Manes collects, uses, discloses, and manages Users’ personal information provided to Mannered Manes when using the Apps, Website, or other Services (as that term is defined in the Terms and Conditions).  This Privacy Policy applies, without limitation, to any individual or entity that (i) uses the Website, Apps, or other Services, (ii) creates an Account (as defined in our Terms and Conditions), or (iii) otherwise provides any personal information to us (the “User”).

WHEN USER ACCESSES OR USES THE SERVICES OR OTHERWISE PROVIDES ANY INFORMATION TO US, USER AGREES TO THIS PRIVACY POLICY, INCLUDING THE MANNER IN WHICH OWNER USES YOUR INFORMATION, WHETHER OR NOT USER HAS AN ACCOUNT WITH MANNERED MANES. IF USER DOES NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES OWNER SUBSEQUENTLY MAKES TO THIS PRIVACY POLICY, USER MUST IMMEDIATELY STOP USING THE SERVICES OR PROVIDING ANY INFORMATION TO US.

The Website and Apps may contain links to other websites. This Privacy Policy does not apply to information collected on or through any such third-party websites or applications. Owner is not responsible for the privacy practices of such third parties. Such third parties have their own privacy policies and User should review those privacy policies to learn about their privacy practices.

Types of data collected

Personal Data includes any information that directly, indirectly, or in connection with other information allows for the identification or identifiability of a natural person.  Mannered Manes may collect, by itself or through third parties, the following Personal Data from Users:  

: 

• Contact and Account Information: User’s name, phone number, email address, username, password, User ID, and any other contact and/or Account information that User provides to Owner, including hair type, descriptions of facial hair or other facial features, and photos.
• Usage Data: Information collected automatically through Mannered Manes (or third-party services employed in Mannered Manes), which can include: the IP addresses or domain names of the computers used by the Users to access the Services, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Apps or Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.  This also includes Information provided through User’s use of the Apps, such as location, a universally unique identifier (UUID), and any other information User or User’s mobile device provides to us.
• Messages and emails:  The date, time, and content of any messages or emails between Owner and User. 
• Payment Information: Credit/debit card and other billing information, including cardholder transaction data, card numbers, expiration dates, billing addresses and CVV codes for any purchases made directly with Owner.  Owner does not collect payment information that User makes through the Apple or Google App stores. 
• Other: Other information User provides to us when using the Services or otherwise interacting with Owner.

Other User data that Owner collects:

• Publicly Available Content. Any information that User makes available through the Services for public viewing, such as information User posts in forums will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. User should exercise caution before revealing any information that may identify User.
• Anonymized Data: Owner may aggregate and/or anonymize any of the above Personal Data so that it is not linked to User and, therefore, is no longer personal identifiable information. 

How data is collected

Personal Data may be freely provided by the User or collected automatically when using Mannered Manes.  For example, Owner may collect Personal Data in the following ways: 

• information User provides when setting up an Account;
• the completion of electronic forms found on the Website or Apps;
• telephone calls between User and Owner;
• referring websites or third parties, including social media sites such as Facebook, Twitter, Tumblr, Instagram, Pinterest, YouTube, Google+ and others including by virtue of advertisements placed by Mannered Manes on websites maintained by those third parties;
• Website server log analysis
• purchases made on the Website; and
• Technology that enables the tracking of Users, for example by accessing or storing information on the User’s device (“Trackers”), such as Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting. 

More information about Trackers 

Trackers enable Owner’s system to recognize Users and Users’ personalized settings, to better understand how Users interact with the Services, to monitor aggregate usage, to optimize traffic routing on the Website or Apps, and to improve its Services in addition to any other purpose described in this Privacy Policy. Most browsers have settings to disable or limit cookies, but certain areas or features of the Services may not be available or fully functional if User disables cookies for the Website. 

No Information collected from children

No information is knowingly collected or retained from children under the age of 13, nor is any such information knowingly used for any marketing or promotional purposes whatsoever, either inside or outside the Website or Apps. No part of the Services is designed to attract anyone under the age of 13. Children are not eligible to use any Services provided and Owner askes that children under the age of 13 not submit any personal information to the Website or Apps.

Any parent or guardian who believes their child has uploaded personal information to Mannered Manes, they should contact Owner at the contact information herein.  If Owner becomes aware that a child has provided it with personal information in violation of applicable law, Owner will delete any personal information collected, unless it has a legal obligation to keep it.

Security

Owner is the controller of Personal Data it collects and takes reasonable precautions to protect the confidentiality and security of User’s Personal Data by using industry recognized security safeguards. Unfortunately, no method of transmission over the Internet is completely secure. Therefore, while Owner strives to protect Users’ Personal Data within industry standards, Owner cannot guarantee its absolute security.

Mannered Manes maintains physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of User Personal Data. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Mannered Manes (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, to process Personal Data by the Owner. Owner’s employees are trained and required to safeguard User’s Personal Data. 

User is responsible for protecting against unauthorized access to their password and computer/mobile device. 

Disclosure of Personal Data

Mannered Manes will not sell your Personal Data for unaffiliated third-party marketing or solicitation.  Mannered Manes may share Personal Data with certain third parties as needed to provide the Services and fulfill the purposes described elsewhere in this Privacy Policy including:

• service providers, such as software infrastructure providers and payment processors, who are only permitted to use the data on Owner’s behalf;
• as necessary to exercise or defend Owner’s rights or comply with applicable law or orders from law enforcement and other governmental authorities; and
• to other third parties with User’s prior consent.

For additional information, see the section on “Detailed information on the processing of Personal Data.”  Additionally, in the event of a merger, consolidation, or acquisition, the data that Owner has collected may be transferred subject to the applicable version of this Policy.

Method, location, and basis for data processing

Location of processing: Notice for international users

The Data processing is carried out using computers and/or IT enabled tools in the United States, following organizational procedures and modes strictly related to the purposes indicated. Information User provides to Owner or that Owner obtains through User’s use of the Services will be processed and transferred to, and be subject to the laws of, the United States. The privacy and data protection laws in the United States may be different from similar laws in User’s country of residence. By using the Website or an Account, or by providing Owner with personal information, User consents to the collection, transfer, storage, and processing of information to and within the United States. If User’s cookies or other software detects IP addresses located in a country outside the United States, Owner reserve the right to deny access to any and all of our services.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Why data is processed 

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Consent: Users have given their consent for one or more specific purposes (e.g., to market products to you, send emails, or use location information). Note: Under some legislations, the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• Performance of a Contract: Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof, including processing payments for and fulfillment of orders User places on the Website;
• Legal Requirement: Processing is necessary for compliance with a legal obligation to which the Owner is subject, including upon request of public authorities or responding to enforcement requests;
• Legitimate Interest: Owner has a legitimate interest in collecting and processing User’s Personal Data to provide its Services and otherwise run a successful commercial organization (e.g. to communicate with User about updates regarding Services, to advertise products, and send Users updates to this policy),  maintain and operate its Services, detect fraud or malicious activity, and/or to protect Owners’ rights and interests, including in connection with legal proceedings arising from improper use of Mannered Manes or the related Services;
• Public Interest: Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

More specifically, Mannered Manes may use Personal Data in connection with each of the following:   

• Analytics, 
• Contacting the User, 
• Content performance and features testing (A/B testing), 
• Hosting and backend infrastructure, 
• Interaction with external social networks and platforms, 
• Registration and authentication, 
• User database management.
• Providing the Services and fulfilling orders
• Managing contacts and sending messages, and
• Social features.

The User may refer to the section “Detailed information on the processing of Personal Data” for additional detail about Personal Data processed in connection with each.  In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

‍

• Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics for Firebase (Google LLC)

Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC.
In order to understand Google's use of Data, consult Google's partner policy.

Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.

Mannered Manes uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.

Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy.

Google Analytics (Google LLC)

Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of Mannered Manes, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

• Contacting the User

Contact form (Mannered Manes)

By filling in the contact form with their Data, the User authorizes Mannered Manes to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data processed: email address; first name; last name; phone number; User ID.

‍

• Content performance and features testing (A/B testing)

The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of Mannered Manes.

Firebase Remote Config (Google LLC)

Firebase Remote Config is an A/B testing and configuration service provided by Google LLC.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

• Hosting and Backend infrastructure

This type of service has the purpose of hosting Data and files that enable Mannered Manes to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Mannered Manes.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Firebase Cloud Firestore (Google LLC)

Firebase Cloud Firestore is a hosting and backend service provided by Google LLC.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

‍

• Interactions with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of Mannered Manes.
The interaction and information obtained through Mannered Manes are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on Mannered Manes isn’t being connected back to the User’s profile.

Facebook Like button and social widgets (Facebook, Inc.)

The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

• Registration and authentication

‍

By registering or authenticating, Users allow Mannered Manes to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Mannered Manes will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

Firebase Authentication (Google LLC)

Firebase Authentication is a registration and authentication service provided by Google LLC. To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform.

Personal Data processed: email address; first name; last name; phone number; username.

Place of processing: United States – Privacy Policy.

‍

• User database management

This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to Mannered Manes, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving Mannered Manes.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Mannered Manes.

Intercom (Intercom Inc.)

Intercom is a User database management service provided by Intercom Inc.
Intercom can also be used as a medium for communications, either through email, or through messages within Mannered Manes. Intercom Messenger may use Trackers to recognize and track Users behavior.

Personal Data processed: Data communicated while using the service; email address; Tracker; Universally unique identifier (UUID); Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

‍

• Providing the Services and fulfilling orders

This type of service allows the Owner to complete its obligations to User when User requests additional services on the Website or Apps or purchases products from Mannered Manes.  These services may collect data concerning the time and date that User schedules consultations, the time, date, and description of purchases made on the Website, and payment information.  

‍

Cal.com (Cal.com, Inc.)

Cal.com is a scheduling platform that enables Users to connect with Mannered Manes, consultants, stylists, and other mannered manes independent contractors for purposes of engaging with Mannered Manes Services.  

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States—Privacy Policy

Shopify (Shopify, Inc or Shopify International Ltd.)

Shopify is an online e-commerce platform through which Owner may sell products on its Website or Apps. 

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of Processing: Canada, United States, Ireland – Privacy Policy

Gumroad (Gumroad, Inc.)

Shopify is an online e-commerce platform through which Owner may sell products on its Website or Apps. 

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of Processing:United States – Privacy Policy

Stripe (Stripe, Inc.)

Stripe is a third-party payment platform integrated in Mannered Manes Services for the purpose of processing payments for merchandise and products. 

Personal Data processed: various types of Data as specified in the privacy policy of the service, including name, credit card information, and zip code.

Place of processing: United States and elsewhere – Privacy Policy

‍

• Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Firebase Notifications (Google LLC)

Firebase Notifications is a message sending service provided by Google LLC. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Firebase Cloud Messaging (Google LLC)

Firebase Cloud Messaging is a message sending service provided by Google LLC. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

SendGrid (SendGrid, Inc.)

SendGrid also known as Twilio SendGrid is a customer communication platform for transactional and marketing emails and messages provided by SendGrid, Inc.

Personal Data processed: email address; first name; last name; phone number; username.

Place of processing: United States – Privacy Policy.

‍

• Social features

Firebase Dynamic Links (Google LLC)

Firebase Dynamic Links is a social feature provided by Google LLC. Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User journey to and within Mannered Manes.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, certain Users have the right to do the following:

• Withdraw consent. If required by the privacy laws in their jurisdiction, Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. If required by the privacy laws in their jurisdiction, Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. If required by the privacy laws in their jurisdiction, Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. If required by the privacy laws in their jurisdiction, Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.  Users have access to most if not all of their Personal Data through their Account and all Users are free to amend or delete such information.
• Restrict the processing of their Data. If required by the privacy laws in their jurisdiction, Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. If required by the privacy laws in their jurisdiction, Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.  Users have access to most if not all of their Personal Data through their Account and all Users are free to amend or delete such information. 
• Receive their Data and have it transferred to another controller. If required by the privacy laws in their jurisdiction, Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Under the California Consumer Protection Act, California residents also have the right to request: 

• information regarding the User’s Personal Data that Owner has collected in the past 12 months (including the categories of Personal Data collected, the categories of sources of such information, and the purposes for which Owner collected such information);
• notice of whether Owner has disclosed User’s Personal Data to third parties in the past 12 months (and if so, what categories of information was disclosed, and what categories of third parties Owner disclosed it to); and
• a copy of User’s Personal Data collected in the past 12 months. 

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as commercially and reasonably possible.

Mannered Manes will not discriminate against you if you choose to exercise any of these rights. To make any of the above requests, User may contact Owner as set forth in this Privacy Policy. Owner may require verification of User’s identity before further processing User’s request. In certain instances, Owner may be permitted by law to decline some or all of such request.

Additional information about Data collection and processing

Information not contained in this policy

This Privacy Policy considers various laws such as the EU General Data Protection Regulation 2016/679 (GDPR), the California Consumer Privacy Act (CCPA), and the Australian Privacy Principles, as well as other data protection and security frameworks.  If User is entitled to any rights or protections under such laws that are not expressly set forth herein, Owner encourages User to notify it of any such rights or obligations to provide Owner the opportunity to comply with such laws to protect Users entitled to their rights and protections.  More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, Mannered Manes may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

How “Do Not Track” requests are handled

Mannered Manes does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

From time to time, Owner may change this Privacy Policy. When it does, Owner will take appropriate measures to inform User, if necessary, consistent with the significance of the changes made. For example, Owner may give Users notice by posting the revised Privacy Policy on the Website or Apps prior to the change becoming effective, sending a notice to Users via email, or updating this page.

Any changes will go into effect on the effective date shown in the revised Privacy Policy. User can see when this Privacy Policy was last updated by checking the Effective Date date at the top of this Privacy Policy. By using the Services or providing information to Owner following such changes, User will have accepted the amended Privacy Policy.  Please print a copy of this Privacy Policy for your records.

‍