When you visit hghair.eu ("Website") engage with social media or adverts and content on third party websites (collectively “Content”)or with us digitally, we collect certain information automatically from your computer, tablet or mobile phone (a “Device”). We place small data files on your Device, known as ("cookies"), to collect and use personal information about you, including to serve interest-based direct advertising. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

Specifically, the information we collect from you automatically will include information like your IP address, Device type (i.e. make and model), unique device identification numbers, browser-type, time zone settings, broad geographic location (e.g. country or city-level location) and other technical information.

We may also collect information about how your Device has interacted with us, including the pages accessed and links clicked, how you navigate to and from our Site and our Content (such as how you scroll over our Site and our Content, which parts you click and how long you spend on each page), your preferences, the products and/or services that you have viewed or searched for, crashes and download errors and response times.

When you: (i) sign-in to our Site using a Social Site or other websites; (ii) access Social Sites using our Site or other websites; and/or (iii) submit content to Social Sites or other websites using our Site, that Social Site or other website may use cookies and similar technologies to collect data about user behavior for their own purposes. This use of cookies is in line with that third party’s own cookie policy, over which we have no control. Please see section “What if I access or use a social network or public forum through a Site?” in our Privacy Notice for further information.

Please see our Privacy Notice for more information about how we use your personal information, how to contact us, and your individual rights.

How can you change your settings?

Upon your first visit to the Site you will be asked to ‘accept’ the use of cookies on the Site for all Site visits using a pop-up message box. If you continue to usethe Site, your use will be treated as consent to the use of cookies.

You can opt out of cookies at any time by following the instructions at the links below for your browser:


Please note that opting out of cookies in one browser, device or app will not necessarily mean that you have opted out of cookies for all of your browsers, devices or apps. Data collected via cookies may be combined with data from other websites, mobile applications and sources.

If you no longer wish to see tailored advertising, you can amend your cookie preferences. In addition, some third party sites allow you to stop seeing advertisements from specific advertisers on that site, so you should also check your preferences on those websites.
 
 
How do we use information we collect about you from the cookies?
We use cookies to:

  • place advertisements for our products on other external sites. We do this by allowing third parties including Google and Adserve to place cookies on our Site which allows them to identify your visit to our Site and preferences shown whilst on it, and your visits to subsequent third party websites in their adserving network. This allows us to serve tailored advertisements to you on those third party websites based on the information we have collected on your interests whilst you were visiting our Site.
  • help the Site to function correctly and ensure that the  ‘add to basket’, navigation and country site settings are maintained.
  • monitor the Site’s performance and ensure that we deliver a fast browsing experience.
  • allow you to share content with social networks, express interest in content and connect with your social media networks.
  • allow us to collect anonymous data about Site usage to help us improve the usability, content and user experience of the Site. This includes site analytics cookies such as Google Analytics. We also use Google Analytics to collect information about your online activity on the Site, such as the web pages you visit, the links you click, and the searches you conduct on the Site.  We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the Site, where visitors have come to the site from and the pages they visited.  For more information about the information gathered using Google Analytics please visit http://www.google.com/intl/en_uk/analytics/tos.html
  • assess third party conversion by allowing us to collect anonymous data about how our marketing is performing;
  • to provide a personalized service, we use your personal information across the Site to provide a seamless user experience;
  • for tailored advertising, we, or with third party vendors, use your information to provide you with tailored advertising on third party sites, including Social Sites. These advertisements are either: (i) “contextual” (meaning they are presented due to the webpage that you are viewing); or (ii) “behavioral advertising” or “interest based advertising” (i.e. where advertisements are shown to you based upon your interests which we have inferred from your information including demographic, geographic and interest-based data). We may use tailored advertising to specifically include or exclude customers who have registered for our products and services to ensure that you are provided with information about those products or services that are most relevant to you. To do this, we may track your browsing activity across different websites, through your Device and/or different applications. We may match your browsing activity on one Device, such as your mobile phone, with your browsing activity on another

Last Modified: 17th Dec 2018


Introduction
Your privacy is important to SMA srl, trading as hg, (“hg", "us", "our", and "we") and we are committed to protecting your personal information. This Privacy Notice ("Notice") relates to our use of your personal information when you:


• Use hghair.eu , or microsites displaying this Notice (collectively, " Sites”);


• Interact with us through social media or adverts and content on third party websites (collectively “Content”);


• Otherwise engage with us, by attending an education event, tradeshow or other hg events.
This Notice explains what information we collect about you; how we use it (including who we share that information with); and your rights and choices regarding your personal information.
SMA srl is the data controller for information processed as described under this Notice. If you have any queries about our processing or how we handle your information please contact us using the details set out in the "Contact Us" section.



• What information does hg collect about me?

The personal information that we may collect about you broadly falls into the following categories:


• Information that you provide directly
When you engage with hg, either online or in person, we will ask you to provide us with personal information about you. If you would like to register an account with us, receive newsletters or information about our products or events; and/or submit enquiries to us, we will need you to provide us your contact details.
You will also provide us with your personal information when you; purchase our products or register a warranty for those products; communicate with us through social media or our customer services teams; join a loyalty scheme or reward program, participate in our promotions, or interact with us at tradeshows or our other events.
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point when we ask you to provide it, and will depend on why you are engaging with us however we may collect:
- Identification information, for example your first name, last name, email address, postal address, date of birth, phone number, gender, country of residence, lifestyle/interests, appearance, style, login name, password, answers to security questions;
- transaction information, for example details regarding your transactions with us, including information about the purchases you made and the date and time that you made the purchase; and/or
- Your opinions or other information, for example if you review the products you have purchased from us, provide information about products and/or hair concerns, and the products you use



• Information that we collect automatically


We also collect information from you automatically and this is explained here: http://www.hghair.eu/en/info/privacy-policy-cookies


• Information that we obtain from third party sources
We also receive information about you from third party sources, but only where we have checked that these third parties either have your consent to share that information with us or are otherwise legally permitted or required to disclosure your personal information to us.

The types of information we collect from third parties includes:
- Our social media partners, if you ‘log-in’ to our Site using a Social Site (as defined in the "What if I access or use a social network or public forum through the Site?" section of this Notice), that Social Site may pass information to us, including: the user ID for that third party site, the name, email address and location associated with the user ID and any other information permitted under the privacy policy for that Social Site. We may also share information about you to that Social Site regarding your login. More information about accessing or using a Social Site can be found in the section “What if I access or use a social network or public forum through the Site?”
- Our retailers, distributors and third party brand partners, our retailers, distributors and third party brand partners may pass information to us including your first name, last name, email address, postal address, phone number, gender, demographic information including information about your appearance (including hair color, hair characteristics; and hair-care routine) and information in relation to products purchased at their stores (whether on the high-street or online through their own website or their dedicated microsite) and services requested using their websites and/or applications.
- Our technology partners and market research organizations, for example where permitted by applicable data protection law our preferred technology partners may share information with us, including your browsing patterns, geo-location and device identifiers.



• How does hg use my information?



We will use your personal information for the purposes set out below:


• To provide you with the products and services that you have requested, to carry out our obligations arising from the relationship between you and us, including providing the products and services to you.



• To verify your identity, for example we may use your date of birth to determine that you are old enough to use our services, when you register your warranty, make a claim on your warranty, log in to your account with the Site, or determine if you already have an account with the Site.



• For our internal administrative purposes.



• To provide a personalized service, we use your information to provide you with personalized recommendations for our products that we think you might like, tailor Content to better suit your interests or, at your request and where available, to offer personalized and customized products .



• For analytics purposes, for example we will analyze your information including your location, products and/or services requested, age, time zone, IP address and URL visited, against our wider customer base to generate statistics and develop marketing plans so we can improve our services and products, the Site, and Content.



• To provide you with marketing communications that you might be interested in, if you choose to receive marketing communications from us, we will use your information to keep you up to date with our latest products, services, surveys, announcements, upcoming events, sweepstakes, contests and other promotions and competitions via our newsletters, emails, or other communications. If you no longer wish to receive these marketing communications, details of how to opt out are described in the section “How do I stop receiving marketing communications?”



• For non-marketing communications, we need to use your personal information to communicate with you important information in relation to your account, the service you have requested or other non-marketing communications. This includes: (i) emailing you to verify your identity when you sign-up; (ii) emailing you where you have requested a password and/or username reset; (iii) notifying you that a particular service has been suspended for maintenance or terminated; (iv) letting you know that we have updated this Notice or our Terms of Use; or (v) letting you know about any products or services that you have requested or purchased. We will never contact you to ask for your password. Please be careful if you receive any communications from people requesting this information.



• To provide you with support, for example as a customer, we may use your personal information to process and respond to your questions and/or inquiries through our customer service process.



• For site optimization and management, for example we will use your personal information provided to us to:



• administer the Site, Content and our other digital offerings, including the services and products offered through the Site;



• ensure the security of our networks and of your information

;



• customize your future visits to the Site and our other digital offerings based on your interests to ensure the most user-friendly online navigation experience;



• improve the Site and our other digital offerings (including to fix operational problems such as pages crashing and software bugs); and



• provide services to our partners such as tools, analyses, data and insights to see how their website or mobile applications are used.



• For product development and business development purposes, we will use information we collect from you to improve our products and develop new products.




• On what basis can hg use my information in this way?

We are required to satisfy one or more of the reasons set out by applicable data protection laws before we can collect and use your personal information.
Generally, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally rely on the following reasons to collect and use your personal information:
What are the legal grounds?
What are they?
Performance of a contract
:
Using your information may be necessary for us to perform our obligations under a contract with you or with a view to entering into such a contract. Where you have requested services and/or products from us, we will need to use your information to provide those services and/or products that you have requested.
Compliance with our legal obligations
:
The collection and use of your personal information may be necessary to enable us to meet our legal obligations. For example, if you are a business customer we need to process your information to verify your identity and undertake necessary compliance checks.
Pursuing our legitimate interests
:
Where such processing is not overridden by your rights, we are permitted to use your personal information to pursue our legitimate interests: to operate the Site and our other digital offerings, to improve our products and services, the Site and our other digital offerings, and to undertake marketing.
Consent
:
In some limited circumstances, we may rely on your consent to collect and use your personal information. We need to rely on consent when we send you e-marketing, or communication from different brands within the group.
If we rely on consent, this will be made clear to you at the time we request your information. You can withdraw your consent at any point by using the mechanism provided at the time, or by contacting us using the contact details provided in the section “of this Notice.
Vital interests
:
In some instances, we may need to use your personal information to protect your vital interests or those of another person.

 

You may not always be required to provide the personal information that we have requested. However, if you choose not to provide certain information, you may not be able to take advantage of some of our services. Any information that is so required is clearly marked as mandatory. If you would prefer that we not collect certain personal information from you, please do not provide us with any such information, or opt out of providing this information where applicable.
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), these interests will normally be as set out in this Notice; however if this changes we will make clear to you at the relevant time what those legitimate interests are.
If you have any questions or need further information concerning the legal basis on which we collect and use your personal information, please contact our Data Protection Officer. Details for how to contact our Data Protection Officer can be found in the section “Contact Us?”
 


• Do we use cookies and other similar technologies?

Learn more about cookies and other similar technologies, including how to amend your cookie settings by referring to our Cookie Policy.
 


• Does hg share my personal information with anyone?

We will disclose your personal information to the following categories of recipients:


• Within the Group: We may make your personal information available to other entities within the Group to allow us to provide our services to you, for the purposes described in this Notice, or as notified to you when we collect your personal information.
 


• With third parties for marketing purposes: Certain promotions and events sponsored by us, or certain portions of the Site, may offer you the opportunity to consent to receive marketing communications from our business partners such as promotion co-sponsors. If you have given your consent, your information may be used by such third party for such purposes;
 


• With our business partners: certain partners offers services through our Site, including credit providers, student discounts and gift cards. Your sue of these services will be subject to the relevant partner’s own privacy policy, so please ensure that you read it.
 


• With our service providers: hg engages third party service providers to perform functions on hg’s behalf ( to support the delivery of our products, services or the Site). The types of service providers we work with are set out below:
- fulfilment partners and third party warehouse providers – who are responsible for helping us to fulfill and deliver your orders and track your products.
- advertising providers – companies that provide: (i) advertising space for hg; (ii) the provision of advertising related services, including agencies instructed to make advertising purchases on behalf of hg, providers of ad-exchanges (a digital marketplace to buy and sell advertising space) and providers of a demand-side platform (software used to purchase advertising in an automated fashion), such as DoubleClick from Google;
- providers of customer relationship management databases and data management platforms – that enable hg to manage our Customer information in a safe and efficient manner;
- data analyses firms – that provide insights and help us to analyze trends using the data that we and they hold;
- marketing campaign companies– this include companies that coordinate email campaigns, sweepstakes, contests or promotions on our behalf; 
- application development and web-hosting companies – to enable the Site to be hosted on the internet;
- information technology and related infrastructure providers;
- email delivery providers;
- audit and professional service providers;




• As part of a business transfers: hg may disclose your personal information to an actual or potential buyer (and its agents and advisers) in relation to any actual or proposed divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding
 


• To comply with laws: hg may disclose your personal information to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person; and
 


• To any other person with your consent to the disclosure.
 


• How do I stop receiving marketing communications?
 
We will only send you marketing communications if you have agreed to this, or if we are otherwise permitted by law. If at any time you decide that you no longer wish to receive marketing communications from us, you may opt out by clicking on the relevant ‘unsubscribe’ link in the email you receive, or by contacting us using any of the methods detailed in section "Contact Us?" of this Notice.
 


• What are my data protection rights?
 
Subject to applicable data protection law, you may also have the following rights:


• The right to request access to, rectification of or deletion of your personal information
 


• The right to request the restriction of our processing of your personal data
 
The right to object to our processing of your personal information (including any processing for direct marketing purposes).


• The right to request portability of your personal information, in certain circumstances.
 


• The right to withdraw your consent, if applicable. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You can exercise these rights by contacting us using the information provided in the section “Contact Us” of this Notice. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws and we may require reasonable documentation to verify your identity prior to granting your request.
If you have any questions or concerns about how we use your personal information, please do not hesitate to let us know.



 


• How long does hg keep my information for?
 
We will retain your information where we have an ongoing legitimate business need to do so (for example, to provide you with access to the Coty Sites or other digital offerings, to provide you with a product you have purchased, or to comply with applicable legal, tax, or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
 


• Does hg transfer my information to other countries?

As an international entity, in order to provide our services we need to transfer and process your personal information internationally (including to destinations outside the European Economic Area (the “EEA”) and the UK), notably throughout the Group and to the jurisdictions in which those entities are based (listed here). This means that when we process your personal information we may process it in any of these countries.
As a result, your information may be transferred to and/or processed in countries outside the EEA which may not guarantee the same level of protection for personal information as the country in which you reside. However, we have taken appropriate safeguards to ensure that your personal information will remain protected in accordance with this Notice. This includes implementing the European Commission's Standard Contractual Clauses for transfers of your personal information between our group companies, which require all group companies to protect personal information that they process from the EEA in accordance with European Union data protection law.
Further information can be provided on request: please contact us using the details found in the section “Contact Us” We have also implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.
 


• Is my information secure?

We understand that you care how your personal information is used and/or shared with others, and we value your trust and seek to safeguard your personal information.
We implement appropriate technical and organizational security measures, including physical, administrative and technical safeguards to protect your personal information from unauthorized access, use and disclosure. To ensure the security of your personal information, we communicate our privacy and security guidelines to all employees and enforce privacy safeguards within our company.
The measures we use to protect your personal information are designed to provide a level of security appropriate to the risk of processing your personal information. However, please be aware that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures that we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective.
 


• What if I access a website through the Site?

As described above, our Site may contain links to and from other third-party websites and services (collectively, “Third Party Sites”) that are not controlled and operated by us.
Please be aware, we have no control over the content, policies or actions of these Third Party Sites. Your use of these Third Party Sites is at your own risk and we do not accept any responsibility or liability for the privacy practices of these Third Party Sites. We encourage you to read the privacy policies and terms of use of each Third Party Site to which you link from the Site.
 
• What if I access or use a social network or public forum through the Site?

The Site may facilitate easy access to certain social networking Third Party Sites and other websites or services with user-generated content features, such as Facebook, Instagram and Twitter (“Social Sites”).
The Site may enable you to:


• access Social Sites: this may include: access to websites such as YouTube; or activation of third party websites when you make a ‘comment’, ‘share’ or ‘like’ something on the Site using a third party social network plug-in. In each instance, such third party’s privacy policy will apply to your interaction with that website or service;


• submit content to Social Sites: for customer reviews, discussion forums, message boards, photographs and other public features (“Public Forums”). We do not restrict the distribution of personal information that you voluntarily disclose in these Public Forums, so please be aware that any information you disclose there may be collected and used by hg and others. For this reason, we encourage you to refrain from providing or sharing personal information about yourself in the Public Forums. hg cannot prevent third parties from using such information in a way that may violate this Notice or applicable law; and


• sign-in to the Site using a Social Site: for a harmonized user experience and for ease of access.
Our use of your personal information in relation to the Social Sites will be as set out in this Notice or as otherwise notified to you. Again, please note that Third Party Sites (including the Social Sites) may be under the control of a third party and we encourage you to familiarize yourself with the privacy policies and terms of use of each Third Party Site.


• How do you process my personal information if I have entered a contest, promotion or survey?

hg and its preferred third party service providers or business partners may offer sweepstakes, contests, promotions and surveys (each, a “Promotion”).
Where we do this, we will use your personal information as set out in this Notice, or as otherwise notified to you. However, in certain cases, a third party’s privacy policy may apply to any personal information that you provide in connection with such Promotion. Before entering any Promotion, we encourage you to check who is operating the Promotion in question, and the terms, conditions, policies and rules that apply to it.
To learn more about the terms and conditions that apply to Promotions being run by hg, please refer to our Promotion Terms and Conditions.





• How old do I have to be to use the Site or other digital offerings?

The Site and our other digital offerings are not directed toward or designed for the use by persons aged 13 and under.
We take your privacy very seriously and we understand the importance of taking extra precautions to protect the privacy and safety of children who use hg's products and services. We do not solicit or knowingly collect personal information from children aged 13 and under.
Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, are not permitted to use the Site or our other digital offerings. If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.
 


• I am a Salon Owner – is there anything else I need to know?
 


Specific provisions apply to Salon Owners that use our Site and our other digital offerings– these are described below.
Each time you submit information relating to a ‘new client’, ‘member of staff’ or other personal data, please make sure that the relevant individual: (i) is over the age of 13; (ii) is aware that you will be sharing their details with us and our processing in accordance with this Notice; and (iii) has, if applicable, consented to receiving marketing communications from us and our affiliates.
You may only share these details with us when using our Site and/or our other digital offerings where you have made those individuals aware of our Notice and how we will use their personal information. If we become aware that you have submitted personal information to our Site and;/or any of our other digital offerings without permission, we will delete the information from our records
 


• I am applying for a job with hg – how do you process my personal data?
 
Thank you for taking an interest in hg. We have a specific privacy notice which applies to our employment process. Please click here
to find out more.
 


• Does this Notice ever change?
 
We may update or modify this Notice from time to time in response to changing legal, technical or business developments. The date of the most recent version of this Notice will appear at the top of the page.
When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. For example, we will notify you of any changes to this Notice by posting a new Notice and updating the “last modified” date at the top of this page or by sending the new Notice to you via email, where appropriate.
 


• Contact Us.


If you have any questions regarding our practices or how we handle your information, please contact us by sending an email to info@hghair.eu or by post to the Sma srl via bianche, 3 36010 Carrè (Vicenza) Italy
 
Thank you for taking the time to read this Notice.


CREDIT PAYMENT OPTIONS
We work with Multisafepay or Paypal because they offer our customers convenient payment methods. Multisafepay or Paypal are a provider of financial services. Head office Kraanspoor 39 1033 SC Amsterdam Postbus 37159 1030 AD Amsterdam The Netherlands P: +31 (0)20 8500 500 E: info@multisafepay.com


We need to provide Multisafepay or Paypal with certain information about you and the order to enable Mulstisafepay or Paypal to assess whether you qualify for their credit products. We need to transfer to Multisafepay or PayPal  account details such as your name, address, email address, phone number, and payment history, as well as your order details, such as payment method, shipping details, what was ordered, and similar. This will not be done if you do not select Multisafepay or PayPal as your payment method. The further use of this data will be governed by Multisafepay or PayPal  Privacy Policy



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