PRIVACY POLICY FOR CALIFORNIA RESIDENTS (CCPA)

Effective Date:  January 1, 2020
Federici Brands LLC trading as COLOR WOW 
195 Danbury Road, 3rd Floor
Wilton, CT  06897
(203) 762-7667
https://www.colorwowhair.com/us

Federici Brands LLC trading as COLOR WOW and its affiliates, hereinafter collectively, "Company" or "we",  respect your privacy and are committed to compliance with the California Consumer Privacy Act (CCPA) effective January 1, 2020.      

This Privacy Notice for California Residents (hereinafter "Notice") supplements the information contained in Federici Brands LLC's US privacy policy (hereinafter "FB Privacy Policy") at https://www.colorwowhair.com/us/privacypolicy (hereinafter “CA Privacy Policy”) and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you").  We adopt this Notice to comply with California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.  

Information Company Collects
Company's website, i.e., https://www.colorwowhair.com/us (hereinafter "Website"), collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("Personal Information").  In particular, Company has collected the following categories of Personal Information from its consumers within the last twelve (12) months: 

Category

Examples

Collected YES/NO

A.  Identifiers

Names, email address, telephone number, email data, User Generated Content ("UGC"), e.g., reviews, photos, etc., or other similar identifiers.  

YES

B.  Personal information categories listed in the California Customer Records Statute (Cal. Civ. Code §1798.80(e))

Names, social security number, address, driver’s license, etc.  Some personal information included in this category may overlap with other categories.  

YES

C.  Protected classification characteristics under
California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, etc.

NO

D.  Commercial information.

Records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.  

YES

E.  Biometric information.

Genetic, physiological, behavioral and biological characteristics, etc. 

NO

F.  Internet or other similar network activity. 

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

YES

G.  Geolocation data.

Physical location or movements.

NO

H.  Sensory data.

Audio, electronic, visual, thermal, olfactory or similar information.

NO

I.  Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J.  Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. §1232g, 34 C.F.R. Part 99))

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, etc.

NO

K.  Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.  

NO


For purposes of this Notice, Personal Information does not include:
Publicly made available information from government records.  

  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA's scope, such as:  
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.  


Use of Personal Information
Company may use or disclose the Personal Information we collect for the business purposes listed in our FB Privacy Policy.   See https://www.colorwowhair.com/us/privacypolicy

Sharing Personal Information
Company does not sell or disclose your Personal Information to third parties for commercial purposes or otherwise except as set forth in our FB Privacy Policy.  See https://www.colorwowhair.com/us/privacypolicy


Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has not disclosed Personal Information for a business purpose.

Sales of Personal Information
In the preceding twelve (12) months, Company has not sold Personal Information.  

California Residents' Individual Rights
The CCPA provides California residents with specific rights regarding their Personal Information.  This section describes your CCPA rights and explains how to exercise those rights.  

Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months.  Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of Personal Information we collected from you.
  • The categories of sources for the Personal Information we collected about you.
  • Our 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 collected about you (also called a data portability request). 
  • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: 
  • sales, identifying the Personal Information categories that each category of recipient purchased; and 
  • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.


Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for the Company or our service provider(s) to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Company with California Electronic Communication Privacy Act (Cal. Penal Code §1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.  

 

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our website.  Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.  You may also make a verifiable consumer request on behalf of your minor child.  

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.  The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format
We try to respond to a verifiable consumer request within forty-five (45) days of its receipt.  If we require more time, we will inform you of the reason and extension period in writing. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.  

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.  

Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”).  We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age.  Consumers who opt-in to Personal Information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting our Website and sending us a message.  

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales.  However, you may change your mind and opt back in to Personal Information sales at any time by visiting our Websites and sending us a message.  We will only use Personal Information provided in an opt-out request to review and comply with the request. 

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights.  Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels.  Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects.  Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

California's "Shine the Light" law (Civil Code Section §1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes.  To make such a request, please send us an electronic message through our Website or write us at our address listed in the Terms and Conditions on our Website https://www.colorwowhair.com/us/customer-service/terms-and-conditions 

Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding your Personal Information.  To learn more about your California privacy rights, visit: https://oag.ca.gov/privacy/privacy-laws.

Changes to Our Privacy Notice
We reserve the right to amend this Notice at our discretion and at any time.  When we make changes to this Notice, we will post the updated Notice on the Websites and update the Notice’s effective date.  Your continued use of our Websites following the posting of changes constitutes your acceptance of such changes.

Contact Information
If you have questions or comments about this Notice, the ways in which we collect and use your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us as follows:

  • Via our Websites:  please send us an electronic message through our Websites; or

Write us at Company's address listed above and in our Terms and Conditions https://www.colorwowhair.com/us/customer-service/terms-and-conditions