Last Updated January 06, 2022
3. Transparency/Notice—Types of Personal Information We Collect and How We Use It
3.1 Types of Personal Information We Collect
We collect Personal Information regarding our current, prospective, and former customers, users, visitors and guests (collectively “Individuals”).
- • Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account with Tippy (“Account”), responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
o Communications with Us. We may collect Personal Information from you such as name, email address, date of birth, phone number or mailing address when you choose to register for an Account, request information about our Services, register for a newsletter or a loyalty program that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.
o Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. We may use such information to improve our Services and in any manner consistent with the policies provided herein.
o Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
• Information from Other Sources. We may receive information about you from other sources, including through Participating Entities and other Third Party services and organizations to supplement information provided by you. For example, we may collect information, such as your name and employee identification number, from Participating Entities to facilitate distributing your tips to you. In addition, if you use Services which involve the use of Tippy third-party partners (see Section 3.5 below) we collect information from these partners in connection with your use of the Services. If you access our Services through a Third Party application, such as an App Store, we may collect information about you from that Third Party application that you have made public via your privacy settings. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our Services.
3.2 How We Use Your Information
We Process Personal Information about Individuals for a variety of business purposes, including:
• To Provide Products, Services, or Information Requested. We may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
o Generally manage Individual information and Accounts;
o Respond to questions, comments, and other requests;
o Provide access to certain areas, functionalities, and features of our Services (such as setting up and operating a digital wallet if you elect to set one up); and
o Contact you to answer requests for customer support or technical support.
• Administrative Purposes. We may use Personal Information about you for our administrative purposes, including to:
o Measure interest in our Services;
o Develop new products and Services;
o Ensure internal quality control;
o Verify Individual identity;
o Communicate about Individual Accounts and activities on our Services and systems, and, in our discretion, changes to any Tippy policy;
o Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;
o Process payments;
o Process applications and transactions;
o Prevent potentially prohibited or illegal activities; and
o Enforce our Terms.
• Marketing Tippy Products and Services. We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Such uses include:
o To tailor content, advertisements, and offers;
o To notify you about offers, products, and services that may be of interest to you;
o To provide Services to you;
o For other purposes disclosed at the time that Individuals provide Personal Information; or
o Otherwise with your consent.
You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 5 below.
• Research and Development. We may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and services. From time to time, we may perform research (online and offline) via surveys. We may engage Third Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other survey participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
• Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on our (or our business partners’) products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 5
• Anonymous and Aggregated Information Use. We may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information with Third Parties for their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
• Invitation to use the Services. Our Services may offer various tools and functionalities. For example, we allow Participating Entities to invite via e-mail service professionals employed by them to use the Services. Email addresses provided by Participating Entities in connection with such functionality of the Services will be used to send the invite to the service professionals, but will not be collected or otherwise used by us or any other Third Parties for any other purpose.
• Other Uses. We may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
• Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site and Services may not work properly.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
• Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
• Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Site or on third party websites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on our Site and Services, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.4 Third Party Websites and Social Media Platforms
The Site may contain links to other websites and other websites may reference or link to our Site or Services. These other domains and websites are not controlled by us, and we do not endorse or make any representations about Third Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
The Site and Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
3.5 Third Party Payment Processing and Services’ Payment Functionality
When you use certain features of the Services that require payment of a fee, we process your payments through a Third Party application. The Third Party application may collect certain financial information from you to process your payment, including your name, email address, address and billing information.
In addition, if you are a stylist or other service professional using the Services’ payment functionality, we may collect certain financial information from you to provide you with such functionality, including your bank account and routing number.
4. How We May Disclose Your Information
4.1 Information We Share
• We Use Vendors. We may share any information we receive with vendors and other providers of services. The types of vendors to whom we entrust Personal Information include, for example, providers of: (i) IT and related services; (ii) information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) services in connection with the provision of the Site or Services. These vendors and other providers of services have access to your Personal Information only for the purpose of performing services on our behalf.
• Business Partners. We may share Personal Information with our business partners and affiliates for our and our affiliates’ and our business partners’ internal business purposes or to provide you with a product or service that you have requested. We may also provide Personal Information to business partners who may offer products or services to you (either individually or jointly with Tippy), or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear either alone or along with Tippy. We require our affiliates and business partners not to use Personal Information for any other purpose other than the purpose for which we provided them.
• Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, we may allow Third Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit Third Party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third Party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 5
• Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) to enforce our policies or contracts; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
• Participating Entities. If you are a stylist or other service professional using our Services, we may share your Personal Information with the Participating Entity which employs you in order to provide the Services to you.
4.2 International Data Transfers
You agree that all Personal Information collected by Tippy may be Processed anywhere in the world, including but not limited to, the United States, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to us, you consent to the storage of your Personal Information in these locations.
5.2 Email, Mail and Telephone Communications
We maintain telephone “do-not-call” and “do-not-mail” lists as required by law.
5.2.1 Mobile devices
We may occasionally send you push notifications through our mobile applications with processing updates, processing milestones and other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
5.3 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
5.4 Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or www.aboutads.info/choices/ . You can also choose not to be included in Google Analytics here.
6. Rights of Access, Rectification, Erasure, and Restriction
You may inquire as to whether we are Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate by using tools available within the Services or by e-mailing us at firstname.lastname@example.org. Where required by applicable law, you also may request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by Tippy. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in accordance with local laws.
Although we make good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
7. Data Retention
8. Security of Your Information
By using the Site, Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site and Services. If we learn of a security system’s breach, we may attempt to notify you electronically by making a notice available to you through the Services or sending an e-mail to you.
9. Children’s Privacy
The Services are not directed to children under 13 years of age, and we do not knowingly collect Personal Information from children under 13 years of age. If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected any Personal Information from children under 13 years old, we will promptly take steps to delete such information and terminate the child’s Account.
10. Redress/Compliance and Accountability
11. Other Rights and Important Information
• New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, we will endeavor to comply with the law or contract.
11.2 California Privacy Rights
The following capitalized terms shall have the meanings herein as set forth below.
• “Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Tippy or to which Tippy discloses Personal Information for use on its behalf.
• “Personal Information” means any information relating to an identified or identifiable natural person (“Individual”).
• “Participating Entity” means a salon or other commercial establishment that has signed up to use the Services in accordance with an Enterprise Services Agreement between such entity and Tippy.
• “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
• “Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Tippy or Tippy Agents.
14. Contact Information. If you have any questions about this Agreement, please contact Tippy at firstname.lastname@example.org.