Accessibility Page 225k 5-star Prose product reviews on Review & Refine™ Menu Get Started Prose Privacy Policy Last updated: September 28, 2020 PerSé Beauty Inc. doing business as Prose ("Prose", "we", "our" or "us") is committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used and disclosed by Prose. This Privacy Policy applies to our Prose mobile application (the "App"); the Prose website at prose.com (the "Site"); and any other website, product or service that links to this Privacy Policy (collectively, including the App and the Site, our "Service"). By downloading, accessing or using our Service, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy and the Prose End User License Agreement and Terms of Service. 1. WHAT INFORMATION WE COLLECT AND FOR WHAT PURPOSE The categories of information we collect can include: Information you provide to us directly. We may collect personal information, such as your name, phone number, mailing address, location, payment information, and e-mail address when you register for our Service, take our personalized haircare survey, order products, or otherwise communicate with us. We may also collect any communications between you and Prose and any other information you provide to Prose. Data collected through the use of the Service. We collect information about how you use the Service and your actions on the Service. Location Information.We collect your unique user identifier and your location through GPS, WiFi, or wireless network triangulation in order to obtain your location for the purposes of providing our Service. We maintain location information only so long as is reasonable to provide the Service and then delete location data tied to your personal information. We may maintain de-identified location data for a longer period of time in order to analyze aggregate trends and metrics. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to limit the Service's access to your location data. Please see "Control Over Your Information" below to learn more. Information we receive from third parties.From time to time, we may receive information about you from third party information providers, or through mergers and acquisitions, and combine this with information previously collected. In these cases, this Privacy Policy governs the handling of the combined personal information. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages and push notifications, and invite others to join the Service. We may also send you Service-related emails or messages (e.g., account verification, change or updates to features of the Service, technical and security notices). For more information about your communication preferences, see "Control Over Your Information" below. 2. HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGY TO COLLECT INFORMATION We, and our third party partners, automatically collect certain types of usage information when you use our Service, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, file information and similar technology (collectively, "tracking technologies"). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, and other such information. We also collect information about the way you use the Service, for example, the site from which you came and the site to which you are going when you leave our Site, the pages you visit, the links you click, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service. When you access our Service from a mobile device, we may collect unique identification numbers associated with your device or our App (including, for example, a UDID, Unique ID for Advertisers ("IDFA"), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device's location by analyzing other information, like an IP address. We may collect analytics data, or use third-party analytics tools including, without limitation, Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which attempt to recognize you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time. We use or may use the data collected through tracking technologies to: (a) provide custom, personalized content and information, including targeted content and advertising; (b) identify you across multiple devices; (c) provide and monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Service; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance our Service. If you would prefer not to accept cookies, you may be able to: (i) change your settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about Flash objects - including how to manage privacy and storage settings for Flash cookies – on Adobe's website or by clicking here. If you choose to delete Flash objects from our sites, then you may not be able to access and use all or part of the sites or benefit from the information and services offered. We and our third party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see "Third Party Tracking and Online Advertising" below. 3. SHARING OF YOUR INFORMATION We may share your personal information in the instances described below. For further information on your choices regarding your information, see the "Control Over Your Information" section below. We may share your personal information with: Other companies and brands owned or controlled by PerSé Beauty Inc., which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Policy; With third parties who may have products or services we think you may enjoy; Third-party vendors and other service providers that perform services on our behalf, including, without limitation, Stripe, as needed to carry out their work for us, which may include identifying and serving targeted advertisements, providing mailing services, providing tax and accounting services, web hosting, or providing analytic services; The public when you provide feedback. For example, if you comment on our social media sites, your information, such as your first name, last initial, state of residence, and your comments, may be displayed on our Site or on our social media pages; Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce the Prose End User License Agreement and Terms of Service or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Prose , our visitors, or others. We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual. 4. CONTROL OVER YOUR INFORMATION Profile and Data Sharing Settings: You may update your contact information, such as your name, and may change some of your data sharing preferences by emailing us at hello@prose.com. Access to your Device Information: You may control the App's access to your device information through your "Settings" app on your device. For instance, you can withdraw permission for the App to access your address book, location, photo stream and camera. How to control your communications preferences: You can stop receiving promotional email communications from us by clicking on the "unsubscribe link" provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., transactional communications, changes/updates to features of the Service, technical and security notices). Modifying or deleting your information: If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at hello@prose.com. We may not be able to modify or delete your information in all circumstances. 5. SMS TEXT MESSAGING We use Iterable, used in conjunction with Twilio, to manage text messaging. You may review Iterable’s privacy policy here, and Twilio’s privacy policy here. If you opt in to receive mobile text messages from us, you will receive messages at the phone number you provide at the time you opt in. For help, you may contact us at hello@prose.com with “SMS Text Messaging” in the subject line. If you would like to stop receiving text messages, please log in to your Prose account and visit your communication settings in your Account Details, or reply STOP to any Prose text message at any time. Message and data rates may apply. 6. THIRD PARTY TRACKING AND ONLINE ADVERTISING We may share, or we may permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of the Service over time so that they may play or display ads that may be relevant to your interests on the Service as well as on other websites or apps, or on other devices you may use. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including hashed data, click stream information, browser type, time and date you visited the site, and other information. This information is used to display targeted ads on or through our Site or on other websites or apps, including on Facebook. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. As noted above, depending on your browser or mobile device, you may be able set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting "limit ad tracking" (iOS) or "opt-out of interest based ads" (Android). To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative's online resources, at http://www.networkadvertising.org/choices, and/or the DAA's resources at www.aboutads.info/choices, and you may also adjust your ad preferences through your Facebook settings. You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at hello@prose.com. 7. HOW WE STORE AND PROTECT YOUR INFORMATION Data storage and transfer: Your information collected through the Service may be stored and processed in the United States or any other country in which Prose or its affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which Prose or its parent, subsidiaries, affiliates, or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy. Keeping your information safe: We care about the security of your information and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through our Service. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations. 8. CHILDREN'S PRIVACY Prose does not knowingly collect or solicit any information from anyone under the age of 13 on through the Service. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at hello@prose.com. 9. LINKS TO OTHER WEB SITES AND SERVICES The Service may contain links to and from third party websites of our business partners, advertisers, and social media sites and our users may post links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third party sites. 10. CALIFORNIA CONSUMER PRIVACY ACT Effective January 1, 2020, if you are a California resident, then you have the following rights: You have the right to request that we disclose to you, not more than twice in a 12-month period, the personal information about you that we collect, use, and disclose during the 12-month period preceding your request, which shall include as follows: The categories of personal information that we have collected about you The categories of sources from which the personal information is collected The business or commercial purpose for collecting or selling that personal information The categories of third parties with whom we share that personal information The specific pieces of personal information we have collected about you The categories of personal information that we have disclosed about you for a business purpose. You have the right to request the deletion of the personal information that we have collected from you. You have the right not to be discriminated against because you exercised your rights under this section of the Privacy Policy, and we will not discriminate against you for doing so. We do not sell and have not sold consumers’ personal information in the preceding 12 months. For purposes of exercising your rights above, please note the following regarding how we collected and used your personal information during the 12 month period preceding the effective date of this Privacy Policy: We collect the categories of personal information as recited in this Privacy Policy in the section entitled “Information We Collect.” We disclose the following categories of personal information for a business purpose: Identifiers such as your first and last name, alias, postal address, IP address, and email address; payment information; commercial information; Internet or other electronic network activity information; visual or similar information. We use the above categories of personal information for our legitimate interests, meaning our interests in conducting our business, fulfilling orders and processing transactions, and managing and providing services to you, which include the activities set forth in the above section of this privacy policy entitled “How We Use the Information We Collect.” Effective January 1, 2020, if you wish to submit a request under the California Consumer Privacy Act, please click here to fill out a request form. You may also email us at hello@prose.com with the subject line “California Consumer Privacy Act Request.” You may have an authorized agent contact submit a request under the California Consumer Privacy Act on Your behalf; however, we require You (1) provide the authorized agent with signed permission to do so and (2) verify Your own identity. If the authorized agent is not an individual having power of attorney, We also require (3) You directly confirm that You provided the authorized agent permission to submit the request. We will need to verify your identity to enable us to process your request. The verification process will include a two-step verification process, where you must enter the email address associated with your Prose account (or, for non-account holders, the email address we have on file for you), receive an email with an authentication code, and enter the code when prompted to do so. Disclosure and deletion is subject to our receipt of a verifiable consumer request and exceptions or limitations established by applicable laws and regulations. Disclosure and/or deletion will not be completed if a consumer request cannot be verified. 11. NEVADA ONLINE PRIVACY LAW If you are a Nevada resident, you have the right to submit a request directing us not to make any sale of personally identifiable information we have collected or will collect about you. We do not sell your personal information. To request confirmation that we do not sell your personal information, please send an email to hello@prose.com with “Nevada Privacy Information” in the subject line of your message. 12. HOW TO CONTACT US If you have any questions about this Privacy Policy or our Service, please contact us at hello@prose.com. You may also write to us at: PerSé Beauty, Inc. 10 Grand Street Brooklyn, NY 11249 13. CHANGES TO OUR PRIVACY POLICY We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change this Privacy Policy in a material manner we will let you know and update the 'last modified' date at the top of this page. We may provide notice of changes to this Privacy Policy through a pop-up or banner within the Service, by sending an email to any address you may have used to register for an account, or through other mechanisms. Continuing to use our Service after we provide you notice of changes to this Privacy Policy means that you are consenting to the changes.