CCPA Privacy Policy

Privacy Policy for California Residents

Last revised on: August 24, 2021

This Privacy Policy for California Residents (“California Privacy Policy”) supplements the information provided in DMP COLOR, LLC, dba dpHUE’s (“dpHUE,” “we,” or “us”) primary privacy policy. It is parallel in scope to our primary privacy policy and applies only to visitors and users of our websites who are residents of the state of California.

If you have questions or concerns about any of the information provided in this California Privacy Policy, or if you need assistance reading or understanding the policy, please contact us using the information provided in the “Contact Us” section below.

Definitions Specific to this Policy

The CCPA includes definitions for terms specific to this California Privacy Policy that do not apply to dpHUE’s primary privacy policy, including the following terms:

Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include publicly-available information obtained from government records; deidentified or aggregated consumer information that cannot be reconstructed to identify you; any information covered under the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act, activities covered by the Fair Credit Reporting Act, or protected health information as defined under the Health Insurance Portability and Accountability Act.

Sale” or “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information by the business to another business or a third party for monetary or other valuable consideration.

Personal Information We Collect and Disclose

The table below describes the categories of Personal Information we have collected in the past twelve (12) months, the sources for each category of Personal Information, the business and/or commercial purposes for which we use each category of Personal Information, and the categories of third parties with which we share each category of Personal Information. As this chart shows, we disclose certain Personal Information to third parties for certain business purposes. We do not sell the Personal Information of minors under 16 years old without affirmative authorization.

Categories of Personal Information
(Examples)
Sources Business or Commercial Purpose Categories of Third Parties with Which Personal Information is Shared

Unique identifiers –Website and App
(Name, signature, address, telephone email, account name, DL number, online identifier, IP address)

● Directly from consumers through the Shopify website
● Website cookies
● Website analytics providers
● Salon Professionals

● To fulfill specific consumer requests
● To enhance the website experience
● For marketing purposes
● To effectuate the dpHUE Professional program with stylists, if a consumer places a dpHUE order using their stylist’s link or code
● To effectuate the dpHUE Professional/Brand Ambassador program, for stylists participating in that program

● Website providers
● Analytics providers
● Advertising providers
● Capital providers

Government ID number – Salon Professionals and App Only
(Social security number or EIN, Cosmetology license image or  number)

● Directly from cosmetologists (not collected from consumers)

● To provide 1099s based on commissions
● To effectuate the dpHUE Professional/Brand Ambassador program, for stylists participating in that program

● Web administrator for payment processing via PayPal

Physical description – Website Only
(Physical characteristics or description via a hair quiz)

● Directly from consumers (if they choose to provide)

● To curate product assortments

● Website providers
● Analytics providers
● Email providers
● SMS providers
● Advertising providers
● Capital providers

Financial information – Website and App
(Bank account number, credit card number, debit card number, or any other financial information)

● Directly from consumers through the Shopify website
● Directly from Salon Professionals through the Shopify website
Note: dpHUE only stores the last four digits of your payment method; when you submit a payment to dpHUE we do not receive your full payment information, instead our payment processor directly receives your payment information.

 

● To process payments

 

● This information is not shared beyond dpHUE/Salon Professionals and Shopify (our payment processor)

 

Protected class data – Website Only
(Directional characteristics that could indicate protected classifications under California or federal law, including: race, ancestry, national origin, age (40 years or older), marital status, sex, via a hair quiz)

● Directly from consumers

● To curate product assortments and create lifestyle and product knowledge based marketing collateral

● Website providers
● Email providers
● SMS providers
● Analytics providers
● Advertising providers
● Capital providers

Purchase history – Website and App
(Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

● Directly from consumers

● To fulfill specific consumer requests
● To enhance the website experience
● For marketing purposes
● To effectuate the dpHUE Professional program with stylists, if a consumer places a dpHUE order using their stylist’s link or code 
● To effectuate the dpHUE Professional/Brand Ambassador program, for stylists participating in that program

● Website providers
● Third party fulfillment centers
● Email providers
● SMS providers
● Analytics providers
● Advertising providers
● Capital providers

Internet activity – Website Only
(Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)

● Website cookies
● Website analytics providers

● To enhance the website experience
● For marketing purposes

● Website providers
● Email providers
● SMS providers
● Analytics providers
● Advertising providers
● Capital providers

Inferences – Website and App
(Inferences drawn from other categories of individual-level information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes)

● Directly from consumers
● Directly from Salon Professionals
● Website cookies
● Website analytics providers
● Advertising providers

● To enhance the website experience
● For marketing purposes

● Website providers
● Email providers
● SMS providers
● Analytics providers
● Advertising providers
● Capital providers

 

Your Rights

If you are a resident of California, you have specific rights regarding your Personal Information.  This section describes your rights and how to exercise them.

Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that dpHUE disclose to you what Personal Information we collect, use, disclose, and sell. You may exercise this right by following the methods described under the subsection titled “Exercising Your Rights” below.

Right to Delete Personal Information

You have the right to request that dpHUE delete Personal Information we may have collected about you. You may exercise this right by following the methods described under the subsection titled “Exercising Your Rights” below.

Please be aware that we may not always be able to delete your Personal Information. For example, there may be business or operational reasons why we need to retain your Personal Information. If we deny your request to delete your Personal Information, we will inform you of the basis for our denial in our response to you.

Right to Opt-Out of Sale of Personal Information

You have the right to opt out of the sale of your Personal Information. You may exercise your right to opt-out of the sale of your Personal Information by following the methods described under the subsection titled “Exercising Your Rights” below. 

Right to Non-Discrimination

You have the right not to receive discriminatory treatment from dpHUE for exercising any of your rights described under this “Your Rights” section. This means we will not treat you differently for exercising any of the rights described above. Please note that a legitimate denial of a request for information, deletion, or to opt-out is not discriminatory, nor is charging a fee for excessive or repetitive consumer requests as permitted by the CCPA.

 

Exercising Your Rights

 

To exercise your rights, you must submit a verifiable request to us. To submit a verifiable request, please follow one of the methods described below.

  • Submit a request through our “Exercising Your Rights” portal, found here: OneTrust Web Form

To verify your request, we will compare the pieces of information that you submit with your request to the Personal Information we have on file to confirm that the data we have identified corresponds to you, and that the person submitting the request is authorized to do so.

You may designate an authorized agent to submit a request on your behalf. Pursuant to the CCPA:

  • Only a business entity or natural person registered with the California Secretary of State may act as an authorized agent.
  • You must provide the authorized agent written permission to exercise your rights under the CCPA on your behalf.
  • We may deny a request from an authorized agent on your behalf 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 the CCPA.
  • Even if you use an authorized agent to exercise your rights under the CCPA on your behalf, pursuant to the CCPA we may still require that you verify your own identity directly to us. This provision does not apply if you have provided with a power of attorney under California Probate Code sections 4000 to 4465.

We will confirm receipt of your request within 10 business days and respond to your rights request within forty-five (45) days from the date we receive it.  In some cases, we may require additional time to complete your request and will inform you if additional time is needed.  Where additional time is needed, we may take up to a maximum of ninety (90) additional days to complete your request.   

 

Additional California Privacy Rights

Shine the Light: California Civil Code Section 1798.83 permits users of our Site who are California residents to request certain information regarding our disclosure of their information to other parties for those parties’ direct marketing purposes. To make such a request, please send an email to privacy@dphue.com with the subject “Shine the Light Request.”

Revisions to this California Privacy Policy

dpHUE reserves the right to amend this California Privacy Policy at our discretion and at any time. When we make changes to this California Privacy Policy, we will post an updated notice on our website with the effective date.

Contact Us

If you would like additional information regarding our California Privacy Policy or if you have any questions about it, please contact us via email at privacy@dphue.com or at the following address:

DMP Color, LLC d/b/a dpHUE
60 South 6th Street, Suite 3900
Minneapolis, MN 55402