Great Clips Privacy Notice

Last Updated and Effective: July 1, 2024

Introduction and Scope

At Great Clips, Inc. (“Great Clips” or “we” or “our”), your privacy is very important to us. This Privacy Notice describes how we collect, use, share, and protect information about you, including when you access our websites (collectively, the “Site”), use our Great Clips® mobile or tablet device application (the “App”), and visit a Great Clips® salon, which are independently owned and operated franchised businesses. Within this Privacy Notice, we will refer to the Site, App, in-salon activities, and communications with us collectively as the “Services.” If you are having issues viewing this Privacy Notice and would like assistance, please email Great Clips at: data.privacy@greatclips.com.

Please note: All Great Clips© salons are independently owned and operated by third party franchisees. Franchisees, not Great Clips, Inc., are responsible for all hiring and personnel matters at their individual salons. Each Franchisee’s collection and handling of job applicant and employee information may vary, and those individual practices are not intended to be covered by this Privacy Notice.

Contents

• Information We Collect
• How We Collect Information
• How We Use Information
• How We Share Information
• Cookies and Similar Tracking Technologies
• Your Privacy Rights and Choices
• How We Protect Information
• How Long We Retain Information
• Transmission Of Information To Other Countries
• Third-Party Websites and Services
• Children’s Privacy
• Changes to this Privacy Notice
• Contact Us
• Additional Information for California Residents

Information We Collect

Depending on the nature of your interactions with us and our Services, we may collect the following categories of personal information:

• Unique identifiers, such as name, address, telephone number, email, birth month, account name, online identifier, IP address.
• Physical characteristics, such as physical description.
• Commercial information, such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information, such as browsing history, search history, and information regarding interactions with website, application, or advertisement. This information may include usage data (e.g., access dates and times, pages or screens viewed, how long you spent on a page or screen, links clicked); information collected through cookies, web beacons and other similar tracking technologies (e.g., operating system name and version, browser type and version); and device information (e.g., hardware mode, operating system and version, identification numbers assigned to your mobile device, mobile network, and website or app usage behavior).
• Geolocation data
• Audio, visual, olfactory information, such as information captured in Clip Notes or shared by customers (e.g., physical features, pictures of customers with haircuts).
• Professional or employment-related information, such as employment history, education, job interest, and licensing information (for job applicants only).
• Education information (for scholarship applicants and job applicants only)
• Inferences drawn from other personal information collected from you or about you, including communication preferences, visit history, and lifestyle details.

Sensitive Information Disclosure

We collect the following categories of sensitive personal information (as defined under California law): social security, driver’s license, state identification card, or passport number (for job applicants only); account log-in in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; information concerning an individual’s health (for job applicants only); and characteristics of protected classifications, such as age, sex, race/ethnicity (for job applicants only). This information is collected in order to process transactions, comply with laws, manage our business, or provide you with services. Note that we do not use such information for any purposes that are not identified within the California Civil Code Section 1798.121. We do not “sell” or “share” sensitive personal information for purposes of cross-context behavioral advertising.

Please note: Great Clips® franchisees may be collecting additional details and information not covered under this Privacy Notice. This could include things like video captured by security cameras or other marketing tools not currently in use by Great Clips, Inc.

How We Collect Information

We collect information about you in a variety of ways depending on how you interact with us and our Services.

We collect information directly from you when you provide it to us, such as when you:

• register for an account;
• fill in a form on our Site, App, or in our salons;
• opt-in to receive text message or App push notifications;
• sign up to receive communications from us, including alerts, industry news, surveys, scholarships, coupons, offers, and other informational or promotional messages;
• participate in surveys or research;
• check-in at a Great Clips® salon or use our Online Check-In function to add your name to a waitlist at a local salon;
• participate in a sweepstakes or other giveaway sponsored by us;
• locate a salon;
• apply for a job or join our Talent Community;
• use our AI-powered automated support chatbot;
• apply for a franchise opportunity;
• register for and/or attend a Great Clips event, including webinars and conferences;
• contact us by phone, email, or otherwise; or
• take advantage of Site or App functionality, or otherwise participate in activities or services generated on the Site or in the App.

We collect information automatically through the use of cookies, pixels, SDKs, server logs, and other similar technologies when you interact with our Services. For more information, please read the “ Cookies and Similar Tracking Technology” section below.

We collect information from third-party sources, including, for example:

• our affiliates, subsidiaries, franchisees and business partners;
• third-party service providers that support our business (such as companies that help us with our marketing efforts, sweepstakes vendors, call centers/chat providers, maintaining and developing the Site or App, data research and analytics, and recruiting);
• online social media networks, and
• publicly available sources.

If you are located in a jurisdiction that requires consent for certain processing activities, our lawful basis for processing your data is generally consent, including implied consent where applicable. If you would like specific information about your consent or right to revoke consent in these jurisdictions, please contact us as indicated in the “Contact Us” section.

How We Use Information

We collect and use information for various purposes, including:

• To provide you access to the Site and Apps, including to create, manage, and maintain the security of your accounts.
• To provide products and services to you, including to provide quality, efficient haircuts with personalized service; facilitate payments and transactions; communicate check-in status, including point-of-sale or app waitlist displays, and provide customer service.
• To communicate with you, including to send haircut reminders and messages about your check-in status; respond to your inquiries and requests; contact you as part of a recruiting, employment inquiry, or job application process; reach out to those who have submitted an interest form for jobs, giveaways, scholarships or recruiting news at Great Clips® salons, provide information related to Great Clips event registration(s), or otherwise provide tailored employment opportunity information; contact customers who may have left a personal item in the salon; or to follow-up on customer feedback.
• To personalize your experience with us, such as displaying your place in line on in-salon waitlist displays and on the App, and customizing emails and promotional mailings.
• To administer your participation in special events, contests, sweepstakes, surveys, or promotions.
• For marketing and advertising, including to send or initiate direct marketing offers or coupons and provide you with advertising about products and services based on your interests through third-party partners.
• To operate and understand your use of our Site and App, including to track Site and App usage and preferences to offer a better customer experience, monitor online and App traffic, troubleshoot issues with the Site or App, and block abusive users of the Site or App, or other security measures.
• For recruiting purposes, including to determine your qualifications and facilitate making hiring decisions.
• For franchise development activities, including to review franchise applications and communicate decisions on applications.
• For business purposes, including to operate and improve our business; conduct research and analytics; perform accounting, auditing and other internal business functions.
• For legal and safety purposes, including to defend or protect us, you, our customers, or third parties, from harm or in legal proceedings; maintain the security of our customers, employees, and property; respond to court orders, lawsuits, subpoenas, and government requests; address legal and regulatory compliance; and notify you of product recalls or safety issues.
• Waitlist displays: we list customers’ first name and last initial on in-salon and App waitlist displays. In the App, your full name will only be visible to you; everyone else will see a first and last initial. This information helps us maintain the waitlist and helps you understand your place in line.

How We Share Information

We may disclose information to third parties, including service providers, business partners, and other third parties, for various reasons. The table below describes the categories of personal information we collect, disclose for a business purpose, “sell” and/or “share” (as those terms are defined by applicable law). Please note, in addition to the recipients identified below, we may disclose any of the categories of personal information we collect with government entities, as may be needed to comply with law or prevent illegal activity. We do not “sell” your personal information for money. As discussed elsewhere in the Privacy Policy, we use cookies and similar tracking technologies for purposes of targeted advertising (also referred to as cross-context behavioral advertising. For more information, please see the Cookie Preferences Center. For details regarding how we use personal information, please see the Information We Collect section of the Privacy Policy. For information regarding how long we retain personal information, please refer to the How Long We Retain Information section of the Privacy Policy.

In addition to the specific disclosures described above, we may disclose any of the categories of personal information we collect in the following situations:

• Corporate Transactions. We may disclose or transfer your information to third parties in connection with, or during negotiations of, an actual or contemplated corporate transaction involving Great Clips, such as a merger, acquisition, divestiture, reorganization, financing or sale of our assets, as well as in connection with an insolvency, bankruptcy or similar proceeding involving us.
• Compliance with Law or Legal Process. We may disclose your information as may be necessary to: (i) comply with applicable law or regulation or a request from a court, regulator, or other governmental entity (such as a subpoena, warrant, court order, or other request ); (ii) enforce our contractual rights and our policies, including in connection with investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, including suspected fraud or security issues; (iv) establish or exercise our rights to defend against legal claims; (v) to protect the rights, privacy, property or safety of us, users of our Site or App, or other third parties; and (vi) to enforce our other legal rights.
• Service Providers. We share your information with service providers. Among other things service providers help us to administer our Site or App, conduct surveys and sweepstakes, provide technical support, process payments, and assist in the fulfillment of services.
• Your Consent. We may disclose your information to other third parties when we have your consent or direction to do so.

Cookies and Similar Tracking Technologies

When you access our Services, we automatically create website and mobile application log files. In addition, we and third parties use technologies—such as cookies, beacons, tags, and software development kits (SDK)— to gather information when you access and use the Services. We use the information we collect to administer the Services, understand how you interact with our Services, analyze trends, and to provide you with advertising about products and services based on your interests.

We may engage in behavioral-based advertising (also referred to as “targeted advertising”). This means that third-party advertising companies may collect information about your use and interactions with our Services over time and across third-party websites and online services, including social platforms, for use in delivering tailored online display and banner advertising to you on other websites and online services. These advertisements may be based on cookies and other technologies to collect and store information about customer interactions with us through our Site or App and interactions with other online services.

For more information about the cookies we use, please see our Cookie Preferences Center.

Your Privacy Rights and Choices

Depending on where you reside, you may have certain rights and choices with respect to your personal information, as described below.

• Access. You may request access to your personal information or confirmation that we have information about you. In certain limited circumstances, you may also request to receive access to your data in a portable, machine-readable format. Moreover, you may request specific third parties to which we have disclosed information.
• Correction. We rely on you to update and correct your personal information. Most of our Services allow you to modify or delete your account profile. If our Sites and/or App do not permit you to update or correct certain information, you can contact us at the address described below in order to request that your information be modified. You may ask us to correct information that is inaccurate or incomplete. Note that we may keep historical information in our backup files as permitted by law.
• Deletion. You may request that we delete your personal information. If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purposes.
• Opt-out of Targeted Advertising/Sharing. You may opt-out of the processing of your personal information for targeted advertising/sharing of your personal information for purposes of cross-context behavioral advertising.
• Marketing Communications. You can opt-out of receiving promotional communications from us by following the unsubscribe instructions in those communications you receive. Please note, if you decide not to receive promotional communications, we may still send you service-related communications.
• Direct Mail. You can elect to be removed from direct mailing activities conducted by Great Clips by submitting a “Do Not Mail” request through the webform on our Site. Please note that while we will work with our service providers to remove your name from Great Clips direct mailings, we cannot guarantee that promotional mailings using alternative addressing formats or addressed to anonymous residents in a certain geographical area (i.e., “Resident at <<address>>”), will also cease, as those mailing lists are not within Great Clips’ direct control.
• Location Data. When installing our App or in subsequent uses, you may have given the app permission to access the precise geolocation data from your phone’s operating system. If you wish to modify this setting, you may do so through your phone’s settings menu. Please review your operating system instructions as they may be different for each operating system and version.
• Do Not Track. Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do respond to browser do not track signals.

Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable law.

If we deny or fail to take action on a privacy request, you may appeal the decision by accessing the Privacy Webform.

How to Submit a Request

• Access, correction, and Deletion. You can make a request to access, correct, or delete your personal information by accessing the Privacy Webform or by calling our toll-free number at 1-888-914-9661, and entering pin 143565. You may also obtain a written form (with a pre-paid envelope) at certain salon locations.
• Opt-Out of Sharing of Information and Targeted Advertising. To opt-out of sharing of information and targeted advertising, use the Privacy Webform to submit a request.

In addition to the webform request, you will also need to customize your cookie settings on the Site and App. You may do so by accessing our Cookie Preferences Center (also available via the Do Not Sell or Share My Personal Information link in the Site footer or App settings) and adjusting your preferences for that web domain or App instance.

Please note: Clearing your browser cookies at any time will undo preferences saved through this process. To re-save preferences, please return to this screen after clearing your cookies. Also, please note that the option selected here will only apply to the device you are currently using.

We also recognize Global Privacy Control (GPC) signals enabled by customers on their web browser or web browser extension as valid opt-out requests where required by applicable law. Please note that your opt-out preference signal will be applied only to your current browser and device. For more information about GPC, please visit Global Privacy Control.

Verification Process

The verification process varies slightly depending on what right you are exercising. However, you can exercise your rights as follows:

• You are not required to create an account to exercise your rights.
• You can make a request by accessing the Privacy Webform (or calling our toll-free line at 1-888-914-9661, pin 143565 or mailing in a paper form, in which case such request will be inputted on your behalf).
• You will be asked to indicate your residency.
• You must then indicate which request you wish to exercise based upon the list of options presented:
  • To request to opt-out of the sale or sharing of your Personal Information/opt out of targeted advertising, provide your first name, last name, phone number, and email, then you must click the verification link in your email for your request to proceed.
  • To request deletion of your Personal Information, provide your first name, last name, email, phone number, country, and state of residency, then click the verification link in your email for your request to proceed.
  • To request access to your specific Personal Information and categorized information, provide your first name, last name, email, phone number, country, and state of residency, then click the verification link in your email for your request to proceed.

IF YOU DO NOT PROVIDE AN EMAIL ADDRESS DURING THIS PROCESS, YOU MAY NOT BE ABLE TO COMPLETE THE VERIFICATION PROCESS OR OTHERWISE RECEIVE RESPONSES DETAILING THE STATUS OF YOUR REQUEST.

If needed, we may reach out to you with clarifying questions to help verify your identity.

Authorized Agents

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. You must provide the authorized agent written permission to exercise your rights on your behalf. We may deny a request from an authorized agent if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof, as permitted by applicable law. Even if you use an authorized agent to submit a request on your behalf, pursuant to applicable law we may still require that you verify your own identity directly to us.

If you are an authorized agent submitting a request on behalf of an individual, you must include a copy of the written, signed permission indicating that you are able to act on that person’s behalf.

How We Protect Information

Great Clips uses appropriate administrative, technical, personnel, and physical safeguards designed to protect the security of your personal information. Please note, however, that no method of transmission over the internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

How Long We Retain Information

Great Clips retains information for as long as is reasonably necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law. The need to retain personal information can vary depending on the type of information and the purpose for which it was collected. For example, we retain personal information to:

• Provide services to our customers who are actively engaging with us and for a set time period thereafter;
• Comply with applicable labor, tax, and immigration laws;
• Comply with other regulatory requirements;
• Investigate security incidents or other investigations as may be necessary;
• Investigate and respond to complaints;
• Preserve intellectual property rights; and
• Assist in the defense or prosecution of any litigated or threatened matters.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.

Transmission Of Information To Other Countries

As a multinational company, we transmit information between and among our affiliates. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By submitting your personal information to us you agree to the transfer, storage, and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States.

Third-Party Websites and Services

The information practices of third-party websites linked to or on our Services, including social media channels, external product listings, or other sites, are not covered by this Privacy Notice. Other sites accessible through our Services have their own privacy notices and data collection, use, and disclosure practices. We are not responsible for the policies or practices of third parties. You should consult each website’s privacy notice if you have any questions about their privacy practices.

Children’s Privacy

Our Site and App are not designed for children, and we do not knowingly collect information online from any person we know is under the age of 18. If you are a parent or guardian of a minor and believe your child has provided personal information to our Site or App that you would like us to delete or provide you with instructions for deleting, please contact us at data.privacy@greatclips.com.

Changes to this Privacy Notice

We may modify this Privacy Notice from time to time and will mark new versions with a corresponding effective date at the top of this Privacy Notice. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. If we make a material change to our privacy notice, we will attempt to notify you through email or through a Site or App pop-up.

Contact Us

If you have questions or concerns about Great Clips’ policies and practices for handling your individual information you may use the following methods to contact Great Clips:

• Call our customer service at 1-800-GREATCLIPS (1-800-473-2825) or send an email to customerservice@greatclips.com.

For additional information pertaining to our privacy practices, please contact our privacy team at data.privacy@greatclips.com.

Additional Information For California Residents

California law requires us to disclose the following additional information related to our privacy practices. If you are a California resident, the following privacy disclosures apply to you in addition to the rest of the Privacy Notice.

California Notice of Financial Incentive

We may provide price discounts or coupons for (1) customers who buy specific products or use specific services; (2) recipients of our mailing list who were presented with and took advantage of an incentive to sign up or to participate in a survey; (3) app subscribers who were presented with and took advantage of an incentive to download the app; and (4) entrants and winners of our sweepstakes (collectively, “programs”). When signing up for a program, we may ask you to provide us with some personal information, including name, email address, phone number, zip code, and birthday. Under California law, our programs might be interpreted as “financial incentive” programs as they involve the collection of personal information. We do not assign a monetary value to the information we collect. Based on our reasonable estimate, the value of your personal information to us is related to the value of the free or discounted products or services that you obtain as part of a program. This value is based on the expenses associated with the program offer and associated operations.

You have the choice to opt-in to or opt-out of our programs at any time through the same means they are offered. You may also contact us for additional information at 1-800-GREATCLIPS or email us at data.privacy@greatclips.com.

California Shine the Light

California Civil Code Section 1798.83 permits users of our web site that are California residents to request certain information regarding our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to data.privacy@greatclips.com with the subject “Shine the Light Request.”

© 2024 Great Clips, Inc.