What data do we gather?

We gather your personal data when you use our website or when you provide them to us directly. The data includes:

• The information that you provide to us when you use our website (e.g., your name, your contacting information, gender, opinion about any products and any other information that you may add to your profile account.
• The information about transactions and billing if you place any order with us or use our website (e.g., credit or debit card details and information about the delivering expenses).
• Record of your interactions with us (e.g., if you contact our customer service team or interact with us via social media).
• The information gathered automatically by cookies and any other tracking technologies (e.g., which websites you have visited or if you have clicked a link from one of our e-mails). We also may gather information about the device you used to enter our website.
• Other data provided to our website, for example, your location, if you give us your consent.

What do we use this personal data for?

Depending on how you use our website, your interactions, and the permissions you provide to us, the purpose of the personal data we gather include:

• Complete your order.
• Manage and respond to any question or reclamation you may make to our customer service team.
• Personalize the website to show you the content we think may be of your interest, based on the information on your account, your purchase history and your browsing activity.
• Upgrade and maintain our website and monitor its usage.
• Marketing studies. For example, we may communicate with you to ask for your opinions about our products.
• Send to you marketing letters and show you personalized advertising, if we have your consent or are allowed to do it.
• For security measures. To avoid and investigate any fraud and, if deemed necessary, for our protection and the protection of third parties.
• To fulfil our regulatory and legal obligations.

We are based on the following legal basis: on virtue of the data protection law, to process your personal data:

There may take place a data processing if it is deemed necessary for the execution of a contract, or before carrying a contract out (e.g., if you make a purchase with ush, we use your personal data to process the payment and place the order). Because we have received your consent (e.g., if you contact us with a consultation, if you add optional information to your account profile, or if you accept to receive our notifications).

Because our legitimate interests, as an online commerce provider, are to maintain and promote our services. We do our best to get as close as we can to our costumers with the purpose of offering them the best products and the best experience. We utilize your information to adapt our website, make it more interesting and relevant according to the products and offers we provide.

Our website allows you to add additional information to your personal account profile like information about your body type, skin type, hair type, hair condition, training regime, goals, height, and weight. We handle this information with special care, for we understand that it may reveal information about your health condition or your ethnicity. If you do not want to, you are not obliged to provide us with such information and you may eliminate it or update it at any time.

Marketing

We love to keep contact with our costumers and, according to your preferences, we can use your personal data to send to you marketing letters via e-mail, phone or postal mail. Some of said messages may be adapted according to your browsing or shopping history, and any information that we may have about you.

To modify your subscriptions, or if at any moment you want to stop receiving our letters (or want to receive them again), you can change your preferences at any given time by contacting us (details below), clicking the “cancel subscriptions” link in any e-mail, or updating the settings from your account. If you cancel your subscription, we can still contact you via the service messages (e.g., order and delivery confirmations, and any information about your legal rights).

Moreover, you may see our advertising on third party websites, or even on social media. Such advertisements adapt by the usage of cookies (that track your online activity and allow us to offer ads to the costumers that have visited our website). The advertising that you may see on social media is due to the fact that we have made a contract with the social network to show our advertisements to our costumers or any other users that may coincide with the demographic profile of our customers. In some cases, this may imply sharing of your e-mail address with the social network. If you do not wish to see personalized advertising, you can change the cookies and privacy settings on your browser and third-party websites.

Who do we share this personal data with?

We share the personal data of our costumers with third parties in the following situations:

• With other companies from our corporation group, if its necessary for the website operation.
• With our suppliers and service providers. E.g., payment processors and delivering companies.
• With our board members and legal consultants.
• With third parties involved with fraud detection and prevention.
• In compliance with the law or any government authorities. E.g., To report a fraud or in response to a legal petition.
• In the event that we sell any commercial asset, the personal data of our costumers may be provided to a possible buyer. In that case, we will do anything we can to guarantee that the buyer complies with the terms of this Privacy Policy.
• If we have your consent or its legally allowed.

Storage and Conservation

We utilize service providers from around the world. Accordingly, your personal data may be processed in countries outside of Europe. Countries where you may have fewer legal rights regarding your data according to the local laws. If we transfer personal data outside the European Economic Area, as stated in the applicable law, we ensure that your privacy rights are adequately protected by the necessary guarantees, specially, the standard contractual clauses of the UE. Please, contact us if you wish to obtain more information in regards to such security measures.

We keep your personal data for as long as necessary for the purposes previously stablished, therefore, this period of time may vary according to your interactions with us. For example, if you placed an order with us, we will keep a record of your purchase for as long as the billing, taxing and guarantee processes may take. We may also keep record of the messages (e.g., if you have filed a complaint regarding a product) for as long as it may be necessary to protect ourselves from a legal reclamation. When there ceases to be a need to keep your information, it will be erased. When you cancel your subscriptions, we will keep your e-mail address with the purpose of not sending you any more e-mails in the future.

Security Measures

Our website guarantees that the data is encrypted as soon as you leave the site. This process implies the conversion of information or data into code to keep it safe from the unauthorized access. The website follows such process and employs secure methods to ensure the protection of every debit and credit card transaction. The encrypting methods, such as SLL, are utilized to protect the customers data as it is transferred to and from the website through a secure communication channel. We do everything we can to ensure that the personal data from our website are protected at any given time, nevertheless, we cannot guarantee the absolute security and integrity of the information broadcasted on our website.

Minors

Our website is not destined and may not be used by anyone under the 18 years of age. We do not gather deliberately any personal data about minors.

Tracking tools and use of cookies

We may collect certain information through cookies, web beacons and other automated means. A cookie is a text file which is stored in a dedicated area of your device’s hard drive, for instance when you visit online service, when you read an email or while installing or using a mobile app. A cookie allows its sender to identify the device on which it is stored during the period of validity of consent, which does not exceed 13 months.

What type of cookies do we use?

• Some cookies may be functional to collect information which will allow Us to facilitate your browsing such as languages preferences, memorizing log-in, or saving the content of your shopping basket or wish list.
• Other cookies also collect information on your behavior by collecting referring URLS (where our visitors come from, which banners they clicked on and which directed them to our website), pages accessed, times of websites visits. Such information will allow Us to enhance our web sites and apps, have a better understanding of the products and services you would prefer, and offer you more personalized communications and/or more personalized content on our website or our applications.
• We also use cookies for web analytics to measure the web sites activity and determine the areas of the web sites which are the most visited, hence improving visibility of our content.
• We use cookies to ensure security of online transactions/purchases through device fingerprinting, which allows to identify certain aspects of the equipment used to place an order.
• Our websites or apps may contain third party cookies (delivered by advertising agencies, analytics providers, etc.) enabling them to collect browsing information on your Devices, including to measure the efficiency of our advertising campaigns on third party websites. Third party cookies are subject to said third party privacy policies. We hereby inform you about the purpose of these cookies and how you can manage them, to the extent we are aware thereof.
• We may include in our website or apps the possibility to share content with third parties or to let other persons know you browsed our website. Such is the case for instance of “Like” and “Share” functionalities offered by social network platforms (“Facebook”, “Twitter”, etc.).

Social networks which offer these functionalities may identify you even though you do not use these functionalities on our website. Indeed, such functionalities allow social network platforms to track information about your browsing on our website whenever your social network account is active while browsing our website.

We do not control how these platforms collect your personal data while you are browsing our website. We invite you to read the Privacy policies of these social networks to find out how they use information they collect (including for advertising purposes) through these buttons. These Privacy policies should provide you information about how to manage your preferences on your social networks account.

Acceptance of cookies

Except for functional or security cookies, the use of cookie on a Device depends on the user’s choice, which can be made and modified freely and at any time.

You can manage cookies either here or by setting your browser to accept or reject cookies on your Device, either globally or cookie by cookie. Settings that you make may change your internet browsing capacity and may sometimes alter your ability to access to certain services that require the use of cookies.

Such is also the case if we or one of our business partners can no longer recognize the type of browser your Device is using such as language, display settings or country / region of connection. We cannot be held liable for the minimized access to our services as a result of cookies you previously deleted or rejected.

Your Rights

You have certain rights in regards to your personal data, including the right to enter and correct your personal data and, in some specific circumstances, transfer your personal data to another company in a common use format.

You have the right to oppose the usage of your personal data for certain purposes, including the sending of advertising. Consult “Marketing” above for more details about how to cancel the marketing subscription.

You also have the right to request the elimination of your personal data, for example, when our personal data gathering purposes have concluded; when you oppose our processing of your personal data in accordance with legitimate interests, and we do not have any imperative and legitimate reasons to continue processing your personal data; and when our data processing was based on your consent which may have been withdrawn.

We will fulfil any request to exercise your rights in accordance with the applicable law. However, keep in mind that there are many limitations to said rights and that there might be circumstances in which we may not be able to fulfil your request. To make a request regarding your personal data, or if you have any question or doubt regarding said information, you must contact us using the details given below. You also have the right to contact you local control authority for data protection.

Contact us

If you have any questions about any aspect of our Privacy Policy, please contact us via our channels shown on the website:

E-mail: info@frontrowco.com