Privacy Policy

Last updated: September 21, 2023

1. General Information

1.1 Introduction

HueSee Inc. (hereafter, “HueSee,” “we,” “our” or “us”) is a Quebec-based company that markets and distributes hairstyling products. Protecting your privacy is important to us. This is why we’ve implemented safeguards and best management practices for your personal information in accordance with applicable laws.

This privacy policy (hereafter, the “Policy”), which must be read in conjunction with the Terms and Conditions of Use of the Website and the Service Agreements with HueSee, describes our practices regarding the collection, use, processing, disclosure and storage of the Personal Information of our customers, visitors and users.

By using our website https://www.hueseehair.com/ (hereafter, the “Website”) or any of our Services, you agree that we may collect, use, process, disclose and store your Personal Information in accordance with the terms described herein. If you do not agree to comply with and be bound by this Policy, you may not access or use our Website or Services or share your Personal Information with us. This Policy is not intended to prevail over the terms of a previous contract with us, nor any right you may have under other applicable laws regarding data privacy.

This Policy does not apply to the Personal Information of our employees, representatives and consultants, or any other person affiliated with us, or to any information that is not Personal Information as defined by the law which modernizes the legislative provisions for the protection of personal information (hereafter, the “Applicable Law” or “Act P 39.1”).


1.2 Privacy Officer

Questions, comments and complaints regarding our Policy and privacy practices may be addressed to our Privacy Officer:

Email:
[email protected]

Address:

2045 Dagenais Boulevard West, Suite 145
Laval, Quebec  H7L 5V1
Canada

2. Definitions

The following words and expressions, when they appear with a capitalized first letter in our Policy, have the meanings attributed to them below unless otherwise noted with an implied or explicit exemption in the text:

“Processing Activity”: The process in which Personal Information is manually or automatically collected or generated by using our Services, by a third party or by another Processing Activity performed by HueSee or one of our subcontractors. For example, how many times a user visits our Website.

“Cookies”: Small text files generated by a website and stored on browsers or devices. They allow to collect certain information when you visit a Website (such as preferences), but may not be used to extract your Personal Information.

“Service Supplier”: Any individual or legal entity that processes data on our behalf. This includes third-party companies or individuals we employ to facilitate our Services, provide Services on our behalf, perform services related to our Services, or assist us in analyzing the use of our Services.

“Personal Information”: Any information that relates to a private individual and allows that person to be identified, i.e. that directly or indirectly reveals something about that person’s identity, characteristics (e.g. abilities, preferences, psychological tendencies, predispositions, mental abilities, character and behaviour) or activities, regardless of the nature of the medium or the form in which the information is accessible (written, graphic, sound, visual, computerized or other).

“Privacy Officer”: The person who is responsible for the application of this Policy and whose contact information is identified in section 1.2.

“Services”: This refers to the website and all related services that we offer such as marketing and distributing hairstyling products and, where applicable, associated media, printed materials and “online” or electronic documentation.

3. Processing Personal Information

3.1 Collecting Personal Information

In our Processing Activity, we may process various types of Personal Information, including:

  • Contact details, such as your first name, last name, address, email and phone number;
  • Professional details or information related to employment, such as your professional training diploma or business card certifying you are a hairstyling professional, which you provide us with when you wish to complete a transaction with us as a professional;
  • Professional details or information related to employment, such as your professional training diploma when you wish to apply to a job with us;
  • Information related to products and/or services, such as details related to the Services we’ve provided you;
  • Information related to transactions and payments, such as the payment method you’ve used, the date and time of payment, the payment amount, your address and other related information;
  • Information that you choose to provide or share with us, for example, when you complete a form, take a survey or contact one of our employees or representatives;
  • Information that concerns you that we receive from third parties such as security service providers, social media platforms, and advertising and marketing partners who monitor, manage and measure our advertising campaigns and which may include your username and other information related to your user profile;
  • Information collected automatically when using our Website and Services, including:
    • Connection details and other information about your activities on our Website, such as your IP address, the pages you have visited, the time and date of your visits, the type of browser you are using, your device’s operating system, and other hardware and software information;
    • Geolocation data, such as your IP address, a precise or approximate location determined from your IP address or your mobile device’s GPS (depending on your device’s settings).

In each case, this personal information is processed in accordance with the purposes listed in section 3.2.


3.2 Personal Information Use

We may use your Personal Information to:

  • Operate, maintain, develop and improve all functionalities of our Website;
  • Execute contracts related to providing our Services;
  • Develop new services, improve our Website, collect opinions and comments regarding our Services, detect and prevent fraud, errors, spam, abuse, security incidents and other harmful activities;
  • Send you messages related to opening and managing your account and inform you about the status of your orders;
  • Perform marketing and business development, including administering a contest, promotion and/or survey, if you have previously consented;
  • Answer your questions and provide you with assistance if required;
  • Conduct research and analysis in connection with our business and Services;
  • Recruit new employees;
  • Any other purpose permitted or required by law.

Please note that we do not use the information we collect for any inference or interpretation whatsoever.


3.3 Personal Information Disclosure

We may disclose your Personal Information to our employees, contractors, consultants, agents, Service Suppliers and other trusted third parties who require such information to assist us in operating our Website, providing our Services, protecting our business or serving you, provided that such Service Suppliers have previously agreed in writing to maintain the confidentiality of your Personal Information in accordance with applicable laws.

We do not sell, trade or otherwise disclose your Personal Information to third parties, subject to exceptions provided by Act P 39.1.


3.3.1 Service Suppliers and Other Third Parties

Although we try to avoid sharing your Personal Information with third parties, we may use Service Suppliers to perform various services on our behalf, such as IT management and security, marketing, analysis, hosting and data storage. We have defined below the cases in which such sharing may take place:

  • We use Google Analytics by Google to analyze our Website audience. See their privacy policy.
  • We use Acceo Ogasys by Acceo Solutions to manage our operations. See their privacy policy.
  • We use OneDrive and SharePoint by Microsoft to store our documents and Outlook by Microsoft to communicate by email. See their privacy policy.
  • We use Mailchimp by Intuit to manage our customer relationships. See their privacy policy.
  • We use Facebook, Messenger and Instagram by Meta to communicate with our customers and prospects. See their privacy policy.
  • We use Moneris Online by Moneris Solutions Corporation for payments on our Website. See their privacy policy.
  • We use Amakai Connected Cloud by Amakai to host our Website. See their privacy policy.

When we disclose your Personal Information to Service Suppliers, we have written contracts with them prior to disclosing your Personal Information to them, and we only provide them with the Personal Information necessary to perform their mandate. As part of these contracts, we are committed to ensuring that the principles set out in this Policy are respected, and these Service Suppliers are required to use your Personal Information in accordance with our instructions and only for the purposes for which it was provided. In addition, these Service Suppliers provide us with sufficient guarantees of the implementation of adequate safeguards that are proportionate to the sensitivity of the Personal Information processed or communicated. When our Service Suppliers no longer need your Personal Information, we ask them to destroy this data in an appropriate manner.

3.3.2 Complying with Legislation, Responding to Legal Requests, Preventing Harm and Protecting Our Rights

In compliance with the applicable laws in force, including those outside your country of residence, we may disclose your Personal Information when we believe such disclosure is authorized, necessary or appropriate, notably to:

  • Respond to requests from public and government authorities, including public and government authorities outside your country of residence;
  • Protect our business;
  • Comply with legal proceedings;
  • Protect the rights, privacy, security and property of us, you and third parties;
  • Allow us to pursue available remedies or limit the damages we may suffer.


3.3.3 Business Transaction

We may share, transfer or disclose, strictly in accordance with this Policy, your Personal Information in the event of a sale, transfer or assignment, in whole or in part, of HueSee or our assets (for example, as a result of a merger, consolidation, change of control, reorganization, bankruptcy, liquidation or other business transaction, including in connection with the negotiation of such transactions). In such a case, we will inform you before your Personal Information is transferred and is governed by another privacy policy.


3.3.4 Personal Information Consent

Whenever possible, we obtain consent directly from the individual concerned for us to collect, use and disclose their Personal Information. However, if you provide us with Personal Information about other individuals, you must have advised them beforehand and obtained their consent.

We will ask for your consent before using or disclosing your Personal Information for purposes other than those described herein.


3.3.5 Personal Information Storage

Subject to applicable laws, we store your Personal Information only for as long as is necessary to fulfill the purposes for which it was collected, unless you consent to your Personal Information being used or processed for another purpose. As a reference, our storage period for some Personal Information can be up to seven (7) years after providing our Services. In addition, our storage periods may be modified from time to time due to legitimate interests (for example, to ensure the security of Personal Information, to prevent abuse and breaches or to prosecute criminals).

For more information on the periods during which your Personal Information is kept, please contact our Privacy Officer using the contact details provided in section 1.2 of this Policy.

We store your Personal Information at our premises located in Quebec or elsewhere with Service Providers who respect the highest technological standards for information security.

We do not collect or store banking information (such as credit card details) used to make purchases on our Website.

4. Your Rights

As the individual concerned, you may exercise the rights set out below by completing the form available here [RM1] and sending it by email or mail to the attention of our Privacy Officer at the contact information provided in section 1.2:

  • You have the right to be informed of the Personal Information we hold about you and to request a paper copy of the documents containing your Personal Information, subject to the exceptions provided by applicable law;
  • You have the right to ask us to have the Personal Information we hold about you rectified, amended and updated if it is incomplete, equivocal, out of date or inaccurate;
  • You have the right to withdraw or change your consent to the collection, use, disclosure or storage of your Personal Information by us at any time, subject to applicable legal and contractual restrictions;
  • You have the right to ask us to cease disseminating your Personal Information and to remove any link that provides access to such information if such dissemination contravenes the law or a court order;
  • You have the right to ask us to delete the Personal Information that we hold about you, subject to the exceptions provided by applicable law;
  • You have the right to ask us to send you your Personal Information or have it sent to another organization in a structured and commonly used technological format;
  • You have the right to file a complaint with the Commission d’accès à l’information, subject to the conditions set out in the applicable law.

To process your request, you may be asked to provide appropriate identification or to identify yourself in some other way.

5. Cookies and Other Tracking Technologies

We use cookies and other similar tracking technologies (hereafter, collectively “Cookies”) to help us operate, protect and optimize our Website and the Services we provide. Cookies are small text files that are stored on your device or browser. They allow us to collect certain information when you visit our Website, such as your language preference, your browser type and version, your device type, and your device’s unique ID. Certain Cookies we use are deleted from your browser after visiting our Website. Other Cookies are stored on your device or browser to enable us to recognize your browser when you visit our Website again. The data collected by these Cookies is not meant to identify you. Cookies notably allow us to operate our Website and to improve your browsing experience. They provide us with certain data that lets us better understand the traffic and interactions taking place on our Website and to detect certain types of fraud. Cookies do not cause damage to your device and may not be used to extract your Personal Information.

You may configure your browser to inform you when Cookies are used when you visit our Website and decide, in each case, to accept or refuse the use of certain Cookies or all Cookies. However, note that deactivating Cookies on your browser can be detrimental to your browsing experience on our Website and prevent you from using certain functions.

To learn more about how we use Cookies, see our Cookies Policy.

6. Security Measures

We have implemented physical, technological and organizational security measures to adequately protect the confidentiality and security of your Personal Information against loss, theft or any unauthorized access, disclosure, reproduction, communication, use or modification. These measures include encryption, access control, segregation of duties to limit access, internal audit, etc.

Despite these measures, we cannot guarantee the absolute security of your Personal Information. If you have reason to believe that your Personal Information is no longer secure, please contact our Privacy Officer immediately using the contact details provided in section 1.2.

7. Changes to This Privacy Policy

We reserve the right to modify this Policy at any time in accordance with applicable law. In the event of a change, we will post our revised Privacy Policy and indicate the updated date. We will also inform you by email at least thirty (30) days before the date the new version of our Policy takes effect. If you do not agree to the new terms of the Privacy Policy, please do not continue to use our Website and Services. If you choose to continue using our Website or Services after the new version of our Policy becomes effective, your use of our Website and Services will be governed by the new version of the Policy.

8. Links to Third-Party Websites

From time to time, we may include on our Website references or links to websites, products or services provided by third parties (hereafter, “Third-Party Services”). These Third-Party Services, which are not operated or controlled by HueSee, are governed by privacy policies entirely separate from and independent of our own. We therefore assume no responsibility for the content or activities of these sites. This Policy applies only to the Website and the Services we offer. Our Policy does not extend to Third-Party Services.

9. Individuals Under 14 Years of Age

We do not intentionally collect or use Personal Information from individuals under 14 years of age. If you are under 14 years of age, you should not provide us with your Personal Information without the consent of your parents or legal guardian. If you are a parent or legal guardian and believe that your child has provided us with Personal Information without your consent, please contact us using the contact details provided in section 1.2 to request that we erase your child’s Personal Information from our systems.

10. Contact Us

Any questions, comments, requests or concerns regarding this Privacy Policy should be directed to our Privacy Officer at the contact information provided in section 1.2.