Privacy Policy

Effective: March 2nd, 2021

This Privacy Policy describes the privacy practices of OWA Haircare, Inc. and its subsidiaries and affiliates (“OWA”, “OWA Haircare” “Susteau” “we”, “us” and/or “our”). This Privacy Policy describes how we handle personal data we collect online (e.g., through our websites and mobile apps), and offline (e.g., through customer support calls and in-person promotional activities) (collectively, the “Services”). This Privacy Policy explains the types of personal data we collect and process, how we may use and share the data, and the choices that are available to you with respect to our handling of your data.

We may collect personal data from various sources, including directly from you, through our websites and mobile apps, from social media or other public forums; and from third party vendors or business partners. The types of personal data we may collect include, contact information, such as your name, email address, mailing address, and phone number, demographic information, such as your date of birth, gender, and zip code, billing information, such as credit card details, billing address, and proof of identification; and when you access the Services through Facebook credentials, the information Facebook makes available to us based on your Facebook privacy settings, such as your name, picture, and email address. Cookies and other information collected by automated means we, our service providers, and our business partners, may also collect certain information about the use of our websites and mobile apps by automated means, such as cookies, web beacons and other technologies. A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server. We and our service providers and business partners may collect information about your online activities over time and across third-party websites.

The information that may be collected by automated means includes, URLs that refer visitors to our websites, search terms used to reach our websites or locate our mobile apps, details about the devices that are used to access our websites or mobile apps (such as IP address, browser information, device information, and operating system information), details about your interaction with our websites and mobile apps (such as the date, time, length of stay, and specific pages accessed during your visits to our websites and mobile apps, and which emails you may have opened), usage information (such as the number and frequency of visitors to our websites); and geo-location data (which determines your current locations) from some of our Services, such as mobile apps. Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time.

We may use the information we collect to fulfill, manage, and send you information about your orders, communicate with you about our Services, including the products we offer and our websites and mobile apps, respond to your requests, inquiries, comments, and suggestions, facilitate your engagement with the Services, including to enable you to post comments and reviews, offer promotions, sweepstakes, or other contests, administer surveys and other market research, conduct research on our customer demographics, interests and behavior, operate, evaluate and improve our business, our websites and mobile apps, and other products and services we offer (including to develop new products and services), tailor the content we display to you in our communications, and in connection with your use of our websites or mobile apps, analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read), provide you with important administrative information regarding the Services such as changes to this Privacy Policy and our Terms of Use and other policies, comply with legal requirements, judicial process, and our company policies (including to verify users’ identity in connection with access or correction requests); and protect against, identify, investigate, and respond to fraud, illegal activity (such as incidents of hacking or misuse of our websites and mobile apps), and claims and other liabilities, including by enforcing the terms and conditions that govern the use of our websites and mobile apps. If we intend to use your personal data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time we collect your personal data.

We may share your information with OWA Haircare, Inc.’s subsidiaries and affiliates, and service providers that perform services on our behalf, or partners with whom we may collaborate, including customer service and support providers, shipping and fulfillment service providers, payment processing providers, partners with whom we jointly develop products or services, survey and market research providers, advertising partners, analytics organizations, and technology providers (including technology support, email and web hosting providers, email and text communications providers, and mobile app developers). We may also disclose your personal data to comply with a legal or regulatory obligation, protect and defend OWA Haircare, Inc.’s rights or property, protect the safety of our customers and website and mobile app users or the public, or to protect against legal liability. Unless prohibited by applicable law, we reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will – where required by applicable law – make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Policy. After such a sale or transfer, you may contact the recipient with any inquiries concerning the processing of your personal data.

You have certain rights and choices regarding our processing of your personal data. Please note that if your exercise of these rights and choices limits our ability to process personal data, we may not be able to provide you with the Services. We reserve the right to verify your identity in connection with any requests regarding personal data to help ensure that we provide the information we maintain to the individuals to whom it pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information. General objections to the processing of personal data

To the extent provided by applicable law, you may withdraw any consent previously provided to us, or object at any time on legitimate grounds, to the processing of your personal information. We will apply these preferences going forward. In some circumstances, withdrawing consent to our use or disclosure of your personal data will mean that OWA Haircare, Inc. may no longer be able to provide you with the Services.

You may request access to the personal data we maintain about you. If we grant your request, we will provide you with a copy of the personal data we maintain about you in the ordinary course of business, in a commonly used format. You may request to correct any errors in your personal data. We may reject your request to access or correct personal data, as permitted by applicable law. If we reject your request, we will notify you of the reason(s) for the rejection. In order to access your personal data, we will require you to provide proof of your identity. This information will only be used for that purpose. Under certain conditions, you may request that we transfer your personal data to another data controller. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reason(s) for the rejection. You may request that we delete your personal data. We may reject your request, as permitted by applicable law. For example, OWA Haircare, Inc. may be required by legal, tax or other reasons to retain your personal information in its business records. If we reject your request, we will notify you of the reason(s) for the rejection.

You may unsubscribe from receiving marketing or other commercial emails from OWA Haircare, Inc. by following the instructions included in the email. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as order confirmation emails or changes in our website or mobile app terms).

Web browsers may offer users of our websites or mobile apps the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites and mobile apps may not function correctly. To support and enhance the Services, we may serve advertisements, and also allow third parties to serve advertisements, through the Services. These advertisements are sometimes targeted and served to particular users and may come from third party companies called “ad networks.” Ad networks include third party ad servers, ad agencies, ad technology vendors and research firms. We are not responsible for the privacy practices of these ad networks and other parties. Advertisements served through the Services may be targeted to users who fit a certain general profile category, which may be inferred from information you provide to us, based on your Services usage patterns, or based on your activity on Third Party Services (as defined in this Privacy Policy). We do not provide personal data to any ad networks for use other than in connection with the Services. Some of our business partners that collect information about your activities on our websites and in our mobile apps may be members of organizations or programs that provide you with choices regarding the use of your browsing behavior for purposes of targeted advertising. Please note that we also may work with companies that offer their own opt-out mechanisms. Geo-location data You may stop sharing your location data by adjusting your mobile device’s location services settings. For instruction on changing the relevant settings, please contact your service provider or device manufacturer.

Some features of the Services allow you to provide content to the Services, such as product reviews. The Services are designed to help you share such content with others. As a result, some of the content that you provide may be shared publicly or with third parties. Our websites and mobile apps do not knowingly collect personal data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided personal data to us through our websites or mobile apps, please contact us, and we will endeavor to delete that information from our databases.

We may provide links to other websites, services, and applications, such as Facebook, that are not operated or controlled by OWA Haircare, Inc. (the “Third Party Services”). The policies and procedures we described here do not apply to the Third Party services. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content, privacy policies, or practices of those Third Party Services. We encourage you to review and understand the privacy practices of any Third Party Services before providing any information to or through them. The Services also may include an activity feed, social media buttons and widgets, such as the Facebook “Like” button or the “Share This” button. Your interactions with these features are governed by the privacy policy of the Third Party Service that provides the feature.

We allow third parties to provide analytics services and serve advertisements on our behalf and on behalf of others across the web and in mobile applications. These third parties may use cookies, web beacons, and other technologies to collect information about your use of our website and other websites, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by us and these third parties to analyze and track data, determine the popularity of certain content, deliver advertising targeted to your interests on other websites and online services, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used in this way, please visit www.aboutads.info/choices.

We may also work with third parties to serve ads to you on our behalf or on behalf of other advertisers on third-party platforms (such as Facebook or Google). As part of these ad campaigns, we or third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us and others to serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

We reserve the right, in our sole discretion, to restrict, suspend, or terminate this Agreement and your access to all or any part of the Services or the Content at any time and for any reason without prior notice or liability, including the right to reject any order you place for the purchase of Products, which may result in the forfeiture and destruction of all information associated with your Account. We reserve the right to change, suspend, or discontinue all or any part of the Services or the Content at any time without prior notice or liability. All provisions of this Agreement which by their nature should survive termination shall survive termination, including, without limitation, licenses of User Content, ownership provisions, warranty disclaimers, indemnity, limitations of liability, class action waivers and arbitration.

OWA Haircare, Inc. maintains reasonable administrative, technical and physical safeguards designed to protect the personal data we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, we cannot guarantee that the measures we maintain will ensure the security of the personal data. Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the data was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired. When we no longer need the personal information we collect, we either irreversibly anonymize the information (in which case, we may further retain and use the anonymized information) or securely destroy the information.

We reserve the right, at our sole discretion, to change or modify portions of this Privacy Policy at any time. If we do this, we will post the changes on this page and will indicate at the top of this page the date this Privacy Policy was last revised. You may read a current, effective copy of this Privacy Policy at any time by visiting this page. We will also notify you of any material changes either through a pop-up notice, email or through other reasonable means. Your continued use of the Services after any such changes constitutes your acceptance of the new Privacy Policy. You should periodically visit this page to review the current Privacy Policy to stay informed of how we are processing personal data.

Under New York Civil Code sections 1798.83-1798.84, New York residents are entitled to ask us for a notice identifying the categories of personal customer data which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a New York resident and would like a copy of this notice, please submit a written request to the following address: OWA Haircare, Inc./Susteau, 64 Bleecker Street #150, New York, New York, 10012, USA Attn: Legal.

Contacting OWA Haircare, Inc./Susteau:

OWA Haircare, Inc./Susteau

64 Bleecker Street #150

New York, New York, USA

hello@susteau.com