1. Information We Collect
When you access our Website or use our Services, we collect certain information about you, including Personal Data and Aggregate Information.
a. Personal Data: This refers to information (either by itself or combined with other information that we have or are likely to obtain) that lets us know, or is capable of letting us know, the specifics of who you are or the household you belong to. Personal Data does not include publicly available information (information that is lawfully made available from federal, state or local government records).
Personal Data may be automatically gathered when you visit our Website. Personal Data can also be voluntarily provided by you. For example, when you engage in certain activities on this Website, or use our Services, we may ask you to provide certain information about yourself. You may also voluntarily provide Personal Data that we did not specifically request, such as by voluntarily posting information on our Website.
b. Aggregate Information: This refers to information that does not by itself, or in combination with other information, identify a specific individual or household, such as demographic or general consumer information (age, gender, general location (such as zip code), general interests etc.) or general Website usage information. Aggregate Information also includes information from which personally identifiable elements have been removed (de-identified). Aggregate Information is sometimes referred to as “non-identifying information.”
For example, we may gather certain information about you, or such information may be automatically gathered, based upon where and when you visit on our Website, how long you are on our Website, and what other sites may have directed you to us. Aggregate Information may be collected in a variety of different ways, and this information may be compiled and analyzed on both a personal and an aggregated basis.
2. How We Collect and Use Your Information
We also collect and use certain Aggregate Information. For example, we may collect and use aggregated IP addresses, Uniform Resource Locators (URLs), browser identification or other software information, etc. to diagnose problems with our servers or software, to administer our Website. We may also collect and use demographic information for marketing analysis.
b. When You Visit Our Website: When you visit or access our Website using a computer, mobile device, etc. (collectively, “Computer”), we may automatically collect and process certain Personal Data about you including (but not limited to) :
- Location data
- Internet Protocol (“IP”) address
- Other identifiable information collected through Cookies (as explained below)
- Usage data
We may also automatically collect and process certain Aggregate Information about you including:
- The Website’s Uniform Resource Locator (“URL”) that points to the site you just came from, which URL you go to after visiting our Website
- What browser or other software you are using
- General location data (e.g., zip code)
We collect and use (for instance, process) this Personal Data and Aggregate Information to better provide you with the content of our Website, including providing you with a better website experience and preparing website statistics, and to provide our Services related to the Website.
c. When You Provide Information to Us: We may require you to provide certain information including Personal Data and Aggregate Information to us when you elect to purchase products or Services from our Website or when you use Services available through or related to the Website. We may receive this Personal Data and Aggregate Information from you through the Website, through other software, by phone, email, or mail etc.
For example, you may provide information to us by doing one or more of the following:
d. Creating or Using a Member Account: Kevin Murphy Group may from time to time offer certain Services to users who have created a member account with Kevin Murphy Group using it platforms, such as the opportunity for accessing previous purchases and status on current purchases, receiving special promotions etc. Other Services we may provide that require a member account include services related to the platform, such as writing articles, uploading pictures etc.
When you create a member account, or use Services that require a member account, we may collect and process Personal Data about you including:
- Your name (first and last)
- A nickname, username, or alias, if provided
- Your email address
- Your mailing address (street name, city or town name, and zip code)
- Your telephone number(s)
- Location data
- Your picture, if provided
- Information about products you used or purchased
- Content you submit, post or access (comments, reviews, articles, pictures, etc.)
- Your Internet Protocol (“IP”) address. We may also collect and process Aggregate Information about you including:
- Your age, if you provide it
- Your gender, if you provide it
- Your general interests, if you provide it
- We collect and use (for instance, process) this Personal Data and Aggregate Information to provide you access to our platform and give you the possibility to use available features in our platform, such as the possibility to connect and chat with other users, view content, etc.
e. Purchasing a Product or Service from Kevin Murphy Group: You can request information from us about a product, or purchase a product or Service from us, with or without creating a member account on Kevin Murphy site. In either case, we may collect and process Personal Data about you including:
- Your name
- Your email address
- Your mailing address (including zip code)
- Your telephone number(s)
- Location data
- Payment information (such as credit card information)
- Session duration
- Product preferences
- Source information
- On site search history
We collect and use (for instance, process) this Personal Data to respond to your request, to provide you with the requested product or service under an agreement between you and Kevin Murphy Group, to comply with our record keeping obligations under the relevant accounting and financial standards that apply to a retail transaction by Kevin Murphy Group and a customer and to otherwise enhance the user experience through our Website.
f. Sending Us a Question or Feedback: If you submit a question or feedback related to Kevin Murphy Group’s products or Services to us (for instance, to customer support), we may collect and process Personal Data included in your question or feedback, and any other Personal Data of relevance to the question or feedback, including:
- Your name
- Your email address
- Your mailing address (including zip code)
- Your telephone number(s)
- Other Personal Data you may include in the question or feedback
We collect and use (for instance, process) this Personal Data to provide customer support, to improve our products and services, and to promote our products and services.
g. Subscribing to Our Newsletter: If you subscribe to our newsletter, we may collect and process Personal Data including:
- Your name
- Your email address
- Favorite Salon
We collect and use (for instance, process) this Personal Data to provide you with our newsletters, and to otherwise enhance the user experience through our Website. You can unsubscribe to our Newsletter at any time, by following the ‘link’ to unsubscribe in our Newsletter.
h. Information that We Collect from Other Sources: We may also collect and process Personal Data and Aggregate Information that we receive from other sources, such as Service Providers (as described below). We may combine this collected information with the other information that we collect as described above. We collect and process this information for the purposes of enhance the user experience through our Website or marketing.
i. Additional Information That We Generate: In addition to the above, we may process Personal Data and Aggregate Information that we collect in the ways described above, for the purposes of better understanding our customers, to ensure that our customers receive relevant marketing, promotion, offers etc. and to enable to continuously improve our website, products and relationships with our customers.
Additionally, this processing may result in the generation of additional information, including Personal Data and/or Aggregate Information. We may collect and use (for instance, process) this additional information to improve our services, products and communication with our customers. For example, we may process the additional information for customer segmentation and analysis.
Depending on how you use our Website, we may store cookies on your Computer to collect certain aggregate data about our users and to customize certain aspects of your specific user experience.
A “cookie” is a small data text file which is stored on your Computer that uniquely identifies your browser. Cookies may also include more personalized information, such as your IP address, browser type, the server your Computer is logged onto, the area code and zip code associated with your server, and your first name to welcome you back to our Website. Cookies delete themselves after a certain period of time (which can vary) but are automatically updated when you visit the website again. On our website Cookies are stored for a period from session duration to 2 years from registration depending on the type of Cookie.
We will not otherwise provide any outside advertising partners with any of your Personal Data, or with any information about your purchases. However, we may use an outside advertising partner to display banner advertisements on our Website. As part of their service, they will place a separate cookie on your Computer. As a result of these separate cookies, our outside advertising partners’ ad server(s) may collect and use Personal Data about you, particularly your IP address. Our outside advertising partners’ ad server(s) may also collect and use Aggregate Information about you, such as your browser type, the server your computer is logged onto, the area code and zip code associated with your server and whether you responded to a particular ad.
We use the following Cookies:
We may use third-party Service Providers to monitor and analyse the use of our Service.
b. Behavioral Remarketing
- Google Ads (AdWords) Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-out Browser Add- on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
- Facebook Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950 To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
c. Use of Data
KEVIN.MURPHY uses the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about, to the extent permitted by the applicable laws
When you are in contact with us on behalf of your employer, we use the collected data for the purpose to communicate with our distributors and/or cooperation partners.
Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some aspects of the Website may not function properly if you elect to disable cookies.
4. Who Can Receive Your Information
Entities Within the Kevin Murphy Group: Kevin Murphy Group may disclose or transfer your Personal Data and Aggregate Information to entities within the Kevin Murphy Group.
Service Partners: Additionally, some of our product and service offerings are facilitated through contractual arrangements made with affiliates, service providers, vendors, partners and other third parties (“Service Partners”). We and our Service Partners may need to use some Personal Data to perform tasks between our respective sites, or to deliver products or services to you. For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on this Website; release your address information to the delivery service to deliver products that you ordered; and provide order information to third parties that help us provide customer service.
Other Service Partners assist us in analyzing how our Services are used. For instance, we may also provide information about our customers’ sales, traffic patterns, and related Website information to third party advertisers, but these statistics do not include any Personal Data.
Service Partners who collect or process your Personal Data on behalf of Kevin Murphy Group may only collect or process such Personal Data in accordance with documented instructions given by Kevin Murphy Group and further terms and conditions stated in a data processor agreement entered into with Kevin Murphy Group. These Service Partners are not permitted to process your Personal Data for their own purposes.
Occasionally we may be required by law enforcement or judicial or regulatory authorities to provide information, including Personal Data or Aggregate Information, to the appropriate governmental authorities. In such cases, we will disclose this information upon receipt of a court order or subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful. Our service partners include the following:
Vendor / Platform - Purpose
- Klaviyo - Email Marketing
- Yotpo - Review, loyalty and customer requests
- Kustomer - Customer Service
- Dash Hudson - Social Media / User Generated Content
- Salesforce (Commerce Cloud)- Web Content Management Platform / Site
- Microsoft - Transactional / Enterprise Resource Planning
- Typeform - Product Matchmaker Quiz
- Funnel - Reporting and analytics
5. How We Store Your Personal Data
a. Retention of Data: Kevin Murphy Group will only store your Personal Data as long as it is deemed necessary to fulfil the purposes for the use of your Personal Data, and to the extent necessary to comply with our legal, regulatory and/or documentation purposes (including to comply with our record keeping obligations under the relevant accounting and financial standards that apply to a retail transaction by Kevin Murphy Group and a customer), resolve disputes and enforce our legal agreements and policies.
If you have a member account on our Website, we will store your Personal Data as long as you have a member account. If you choose to delete your account, we will delete your Personal Data shortly thereafter, unless we deem it necessary to continue storage of your personal data for a specific period for legal, regulatory or documentation purposes.
If you are a customer, Kevin Murphy Group will retain and use Personal Data about you until either termination of the contractual relationship (if any), as long as we communicate, or until it is no longer necessary for the establishment, exercise or defense of a legal or ethical claim.
Kevin Murphy Group will in other cases retain and use your Personal Data as long as it is necessary to send you emails or SMS messages with direct marketing including newsletters, promotions, offers and other relevant information via e-mail or SMS, or until you withdraw your consent. If you withdraw your consent Kevin Murphy Group may store your Personal Data, including your consent to the use of that Personal Data, for as long as the regulations in the relevant territory mandate that your Personal Data can be kept for documentation purposes.
b. Transfer of Data: Your information, including Personal Data and Aggregate Information, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
For example, if you are located outside the United States and choose to provide information to us, please note that we may transfer the data, including Personal Data, to the United States and process it there. On the other hand, if you are located inside the United States and choose to provide information to us, please note that we may transfer the data, including Personal Data, outside of the United States and process it there.
6. Security of Your Personal Data
The security of your data is important to us. We use security software to protect the confidentiality of your Personal Data. In addition, our procedures are reviewed periodically for compliance with policies and procedures governing the security and confidentiality of our information. Our procedures limit employee access to confidential information and limit the use and disclosure of such information to authorized persons.
If information is transferred to entities with the Kevin Murphy Group or to our Service Partners, we will take reasonable steps to ensure that your data is treated securely.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to use commercially acceptable means to protect your Personal Data, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Website cannot be guaranteed.
To serve you most effectively, credit card transactions and order fulfillment are handled by established third party banking institutions and processing agents. They receive the information needed to verify and authorize your credit card or other payment information and to process and ship your order.
Your access to some services and content is password protected. We advise that you do not disclose your password to anyone. In addition, we recommend that you sign out of password-protected services at the end of your Website session.
7. Updating and Correcting Information
We believe you should have the ability to access Personal Data that you have provided to us, and to update and correct it.
You may change any of your Personal Data in your account online at any time through your account if you have established one.
You may also access, review and correct your Personal Data by emailing or writing us at: email@example.com or at one of the following addresses:
Privacy Officer North America
KEVIN.MURPHY USA Ltd.
6440 S. Wasatch Blvd, Suite 150,
Holladay, UT 84121
Privacy Officer EMEA
KEVIN.MURPHY Europe A/S
DK-1432, Copenhagen K
Please include your name, address, and/or email address when you contact us.
We encourage you to promptly update your Personal Data if it changes. You may ask to have the information on your account deleted or removed; however, some information, such as past transactions, logs of technical support calls, or other information may not be deleted. In addition, it may be impossible to completely delete your information without some residual information because of backups.
8. User Choices on Collection and Use of Information
We may, from time to time, send you email regarding new products and services that we feel may interest you. In addition, if you indicated upon registration that you are interested in receiving offers or information from us and our partners, we may occasionally call or send you direct mail about products and services that may be of interest to you. Only Kevin Murphy Group (or agents working on behalf of Kevin Murphy Group and under confidentiality agreements) will send you these solicitations, and only if you have previously indicated that you wish to receive them. If you do not want to receive solicitations from us, you can “opt-out” at any time, by following the ‘link’ to unsubscribe in such offers and mailings.
You also have choices with respect to cookies, as described above. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of our Website may not work properly in your case.
9. Additional Information and Rights for California Residents Note: the home page should have a separate link to this section entitled “Your California Privacy Rights”
A. No Disclosure or Sale of Personally Identifiable Information Without Permission: We will not disclose or sell any personally identifiable information (“PII”) of a user to any third party without first receiving that user’s permission.
B. Categories of Personally Identifiable Information We Collect About Consumers: We may collect the following categories of PII, for the following purposes:
i. Identifiers (real name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, or other similar identifiers);
ii. Record-related personal information (signature, physical characteristics or description, telephone number, education, employment, financial account information)
iii. Commercial information (including records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
iv. Geolocation data;
v. Biometric information;
vi. Internet activity (browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement);
vii. Audio, electronic, visual, thermal, olfactory, or similar information;
viii. Professional or employment-related information
ix. Education information (that is not publicly available):
x. Information generated from inferences from personal information used to create a profile about a consumer that would reflect preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities;
C. Categories of Sources from Which We Collect Personally Identifiable Information:
i. Online order histories
ii. Online forms
iii. Online forums
iv. Retail Partners
v. Marketing companies
vi. Tracking pixels
viii. Web Beacons
D. Categories of Personally Identifiable Information We Have Collected About Consumers in the Previous Twelve Months:
No disclosure required as at 1 July 2021 the organization has not implemented personal information collection processes but gives notice that it will be doing so after this date.
Sharing of Personally Identifiable Information About Consumers: We may share personally identifiable information we collect with third parties in the following categories:
i. Advertising networks
ii. Internet service providers
iii. Data analytics providers
iv. Government entities
v. Operating systems and platforms
vi. Social networks
vii. Data brokers
E. Categories of Personally Identifiable Information We Have Sold in the Previous Twelve Months:
No disclosure required
F. Categories of Personally Identifiable Information We Have Disclosed for a Business Purpose in the Previous Twelve Months:
No disclosure required
G. Right to Request Access to Personally Identifiable Information: You can request access to all your PII by sending an email to firstname.lastname@example.org
Upon receiving a verifiable request, we will provide to you information collected in the preceding twelve months regarding: the categories of PII that we have collected regarding you; the categories of sources from which the PII is collected; the business or commercial purpose for collecting or selling PII; the categories of third parties with whom we share PII; the specific pieces of PII that we have collected regarding you; and the categories of your PII that were sold or disclosed for business purposes in the twelve months preceding your verifiable request.
H. Right to Deletion of Personally Identifiable Information: You have the right to request that we delete any PII about you on this page or on the home page of this Website, by sending an email to email@example.com.
However, we will not be required to comply with a request to delete your PII if it is necessary for us or a service provider to maintain the PII to:
- Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
- 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 business’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent;
- Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business;
- Comply with a legal obligation; or
- Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
I. Right to Opt-out of Sale of PII: You have the right to request that we not sell your PII. This is referred to as the right to “opt-out.” You can make this request by sending an email to firstname.lastname@example.org.
J. Right of Nondiscrimination: We will not discriminate against you because you exercised any of your rights under this section, including: denying goods or services to you; charging you different prices or rates for goods or services, including through the use of discounts or other benefits; imposing penalties on you; providing you with a different level or quality of goods or services.
However, we reserve the right to charge you a different price or rate or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to us by your data.
K. Website not Intended for Children Under 18: You must be at least 18 years old to have our permission to use this Website. Our Website and Service are not intended for, and do not address, anyone under the age of 18 (“Children”). We do not knowingly collect PII from anyone under the age of 18, nor do we knowingly sell such PII.
l.Tracking and “Do Not Track” Signals Under the California Online Protection Act (CalOPPA):
Our Website and Services use tracking methods. Third parties may collect personally identifiable information about an individual consumer’s online activities on our Website.
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
10. Additional Rights and Notices for Nevada Residents
We do not sell (that is, exchange for monetary consideration) any Covered Information of a user to any third party without first receiving that user’s permission. “Covered Information” includes: first and last name; home or other physical address; email address; telephone number, social security number (SSN); an identifier that allow a specific person to be contacted individually or online; or other information concerning a person collected from the person through an Internet website or online service and maintained by the operator in combination with an identifier in a form that makes the information personally identifiable.
However, if we sell covered information in the future, you have the right to request that we not sell your covered information. This is referred to as the right to “opt-out.” You can make this request by sending an email to email@example.com , or by calling the toll-free number listed above.
Third parties may collect information about a user’s online activities through our Website over time and across different websites or online services.
11. Children’s Privacy
You must be at least 18 years old to have our permission to use this Website. Our Website and Service are not intended for, and do not address, anyone under the age of 18 (“Children”). We do not knowingly collect Personal Data from anyone under the age of 18.
If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.
12. Access to Website by Others.
You should also be aware that when Personal Data is voluntarily disclosed (for instance, your name, email address, etc.) in the discussion forums or other public areas on this Website, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages (including unwanted spam messages) from third parties. Such activities are beyond our control and this Policy does not apply to such information. Please consult our Website Terms and Conditions for our Website Conduct policies.
13. Links to Other Sites
14. Your Data Protection Rights Under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. KEVIN.MURPHY aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
6440 S. Wasatch Blvd, Suite 150, Holladay, UT 84121
Kevin Murphy Europe A/S
DK-1432 Copenhagen K