PRIVACY POLICY 

Last updated and effective date: November 2, 2022

J&D Brush Co. LLC (“Wet Brush,” “The Site,” “we,” “us,” or “our”) respects your concerns about privacy. This Privacy Policy applies to personal information we collect on this website and through our mobile application (collectively, the “Services”).

The Privacy Policy describes the types of personal information we collect through our Services, how we may use that information, with whom we may share it and the choices available regarding our use of the information. The privacy policy also describes the measures we take to protect the security of personal information and how to contact us about our privacy practices. By visiting the site, you accept the practices described in this privacy policy.

Information We Collect And How We Use It

You may provide personal information (such as name, contact details, and payment information) through our website, mobile applications, or any other applications or services that link to this privacy policy, visit us in our stores, communicate with us, shop with our third-party partners, engage with us on social media, or participate in any of our programs or events.

We may provide different or additional privacy notices in connection with certain activities, programs, and offerings.

Our websites may include links to websites and/or applications operated and maintained by third parties. Please note that we have no control over the privacy practices of websites or applications that we do not own. We encourage you to review the privacy practices of those third parties. 

Below are the ways you may provide information and the types of information you may submit. We also tell you how we may use the information. 

What Personal Information We Collect 

The types of personal information we obtain about you depends on how you interact with us and our products and services. When we use the term “personal information,” we are referring to information that identifies, relates to, describes, or can be associated with you (such as name, contact details and payment information). The following are the categories and specific types of personal information that we collect: 

Identifying Information 

Including, but not limited to, your full name, address, e-mail address, phone number, date of birth, account name, username or social media handle, and/or other similar identifiers. 

Device Information and Other Identifiers 

Including, but not limited to, device identifier, internet protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifier, Internet/Network Activity (browsing history, website interactions, mobile applications, e-mails, advertisements), geolocation data (whether manually provided or enabled from a mobile device) and/or other similar identifiers. 

Payment Information 

Including, but not limited to, credit or debit card numbers, billing address and other related information. 

Purchasing History 

Including, but not limited to, products or services you have purchased, returned, exchanged, or considered, preferences, and rewards activity related to our upcoming loyalty program. 

Personal Characteristics and Demographic Data 

Including, but not limited to, hair color and type, eye color, skin tone and other beauty profile information you elect to provide. Demographic data including, but not limited to age, gender, race and ethnicity, some of which may include characteristics of protected classifications under state or federal law. 

User Content 

Including your communications with us and any other content you provide (such as social media profiles, photographs, images, videos, survey responses, comments, product reviews, testimonials, and other content). 

Audio and Visual Information 

Including photographs, images, videos, you may elect to provide and recordings of your voice (such as customer service calls recorded for quality assurance). 

How We Collect Your Personal Information 

We collect personal information about you from various sources. For example, we collect and obtain information: 

Directly from you 

We collect personal information you provide, such as when you make a purchase, register for an account or create a profile, sign up for our upcoming loyalty program, contact us, respond to a survey, participate in our sweepstakes, contests, or other similar campaigns or promotions, or sign up to receive emails or text messages. 

Personal Information Connected by Automated Means 

We obtain certain personal information by automated means when you visit our website, use our mobile applications, open or click on emails we send you, or interact with our advertisements. Such information is collected through cookies, web beacons, clear GIF, pixels, internet tags, web server logs and other data collection tools. The information we collect in this manner includes the IP address of the device you use to connect to the internet, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our site, dates and times of website visits, and the pages accessed. By collecting this information, we learn how to best tailor our websites to our customers and understand what products and services you might prefer. Both we and others (such as our service providers) may collect personal information about our visitors’ online activities over time and across third-party websites. 

For more information, please see “Cookies and Similar Tracking Technologies” section below. 

From Social Media Platforms and Networks 

If you interact with us on social media or use features, such as plugins, widgets, or other tools made available by social media platforms or networks (including, but not limited to, Instagram, Facebook, Yptpo, Google and You Tube) in connection with our websites or our mobile application, we collect information that you share with us, or that the social media platforms share with us. For more information about the privacy practices of those social media platforms, please review the privacy policies and settings of the social media platforms and networks that you use. 

From Other Sources 

For example, we may obtain information about you from other sources, such as data analytics providers, marketing or advertising service providers, fraud prevention service providers, vendors that provide services on our behalf, or publicly available sources. We also create information based on our analysis of the information we have collected from you. 

Cookies and Similar Tracking Technologies 

Wet Brush and its third-party service providers (such as its advertising and analytics providers) use cookies, web beacons, clear GIF, pixels, internet tags, and other similar tracking technologies to gather information when you interact with our websites, our mobile application, and email communications. Some tracking technologies help us maintain the security of our websites and your account and from similar events. These tracking technologies are “necessary” because they are essential for the website to work properly. Accordingly, we do not provide the option to opt-out of these tracking technologies, but you can remove these tracking technologies by modifying your browser settings. Please note, some features of our websites may not be available to you as a result. 

We permit third parties to use tracking technologies on our website and  mobile application for analytics to understand how visitors interact with our websites and the mobile application.  For example, we use Google Analytics Instagram and Facebook to measure the effectiveness of our advertising and determine how visitors use our websites. These service providers’ tools, including cookies and web beacons, allow us to collect information such as the state and ZIP code from which our visitors come and the IP addresses of our visitors’ computers.  

For more information about how Google collects and processes data visit https://policies.google.com/technologies/partner-sites. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/. 

We may collect information about your online activities on our websites to provide you with advertising about products and services tailored to your individual interests. We also may obtain information for this purpose from third-party websites and apps on which our ads are served. This section of our privacy police provides details and explains how to exercise your choices. 

You may see certain ads on other websites and apps because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based, and contextual means. These partners track your online activities over time and across websites and apps by collecting information through automated means, including through the use of third-party cookies, web server logs, and web beacons. They use this information to show you advertisements that may be tailored to your individual interests. This data collection takes place both on our website, mobile application and on third-party websites and apps that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. For example, we utilize targeted advertising services to show you our ads on other websites based on your prior visits to our sites and other online activity. Please contact us at help@bbicompany.com to opt out of this feature. 

To learn how to opt out of ad network interest-based advertising generally in the U.S., please visit both www.aboutads.info/choices and http://www.networkadvertising.org/choices/. 

How We Use Your Personal Information 

We collect and use personal information for various purposes, including: 

Providing Products and Services 

We use your personal information to provide products and services, such as to fulfill your orders and/or complete the transactions you request; process your payments; provide you receipts and order updates; send notifications to you related to your account, purchases, returns, exchanges, subscriptions, and reservations; and create, maintain, and otherwise manage your account, profile, or any loyalty program membership, including offering functionalities such as easy checkout and the ability to save user preferences and transaction history. 

Depending on the products and/or services you request, the categories of information used for these purposes may differ. For certain services, you may choose to provide physical characteristics.  

Communicating With You 

We use your personal information to communicate with you, such as to respond to and/or follow-up on your requests, inquiries, orders, and to provide customer service.  

Use for Marketing and Promotional Purposes 

We use personal information for marketing and promotional purposes, such as to send marketing, advertising, and promotional communications by email or text messages, to show you advertisements for products and/or services tailored to your interests on social media and other websites, and to administer our sweepstakes, surveys, contests, and other similar promotions. 

Analytics and Personal Experience 

We use personal information to conduct research and analytics, including to improve our services and product offerings; to understand how you interact with our website, our mobile application, advertisements, and communications with you, to determine which of our products or services are the most popular, and to improve our website, mobile application, and marketing campaigns; to personalize your experience, to save you time when you visit our website and our mobile application, and to customize the marketing and advertising that we show you; to understand how you use our mobile application; to create a more personalized experience for you when you visit our stores; to provide services, to better understand our customers’ needs, and to provide personalized recommendations about our products and services. 

Security and Fraud Prevention 

We use personal information to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions, attempts to manipulate or violate our policies, procedures, and terms and conditions, security incidents, and harm to the rights, property, or safety of Wet Brush and our users, customers, employees, or others. 

Legal Requirements 

We use personal information to comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim. 

How We Share Your Personal Information 

In addition to the specific situations discussed elsewhere in this privacy policy, we disclose personal information in the following circumstances: 

Corporate Affiliates 

We may share personal information with our corporate affiliates, including our parent company, sister companies and subsidiaries. Such corporate affiliates process personal information on our behalf as our service provider, where necessary to provide a product or service that you have requested, to use of any loyalty program, or in other circumstances with your consent or as permitted or required by law. 

Service Providers 

We share certain personal information with third parties that perform services to support our  business and internal operations including, but not limited to: fulfilling orders, delivering packages, complying with your request for the shipment of products to or the provision of services by a third party intermediary, sending mail, e-mails and text messages, analyzing customer data, providing marketing assistance, managing our ratings and reviews programs, supporting beacons, processing credit card and debit card payments, investigating fraudulent activity, conducting customer surveys, sweepstakes and providing customer service. 

Social Media Platforms and Networks 

Our website may contain features such as, plugins, widgets, and/or other tools made available by third parties that may result in information being collected or shared between us and the third party. For example, if you use Instagram’s “like” feature, Instagram may register the fact that you “liked” a product (by putting a heart next to it) and may post that information on Instagram. Instagram’s use of your information is not governed by this privacy policy. Wet Brush reserves the right to use such information. 

Public Forums 

Our website may provide the opportunity to post content in a public forum. If you decide to submit information in these public forums, that information will be publicly available. 

Legal Process 

We also may disclose information about you (i) if we are required to do so by law or legal process (such as a court order), (ii) in response to a request by law enforcement authorities, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We also reserve the right to transfer personal information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information. 

The personal information may be transferred to its affiliates and third party service providers in other countries than the country in which you originally provided it, including the United States.  

Other Instances 

We may ask if you would like us to share your information with other third parties who are not described elsewhere in this privacy policy. 

How We Protect Your Personal Information 

We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide through our Services against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use and other unlawful forms of processing. However, we cannot guarantee or warrant the security of any information you transmit to us and you do so at your own risk. No internet or email transmission is ever fully secure or error-free. You should use caution whenever submitting information online and take special care in deciding what information you send to us via email or message. 

Updates and Corrections 

You can update information related to your account by: logging into your account on wetbrush.com or calling 1-800-5-BEAUTY (1 800-523-2889) Monday - Friday (9am- 5pm EST). 

If you have given us permission to store your credit card information and you don’t want us to receive your updated credit card information through your credit card issuer’s account updater service, please contact your card issuer. 

Managing Communication Preferences 

Email 

You can stop receiving promotional e-mails at any time by clicking on the “unsubscribe” link at the bottom of any promotional e-mail that you receive or logging into your account, clicking on the “My Account” page and managing your e-mail preferences there. 

Text Messages 

You can opt-out of receiving text messages from us by replying “STOP” to the text message you receive from us. Please note that this will only opt you out of the specific text messaging program associated with that number.  

In-App Push Notifications 

You can stop receiving in-app push notifications in our mobile application by adjusting your Notification Settings in the application. 

Removing Content from Public Forums 

You can request that we remove content or information that you have posted on a public page on our website or mobile application by e-mailing details to Customer Service at help@bbicompany.com. Please note that while we will attempt to honor your request, the removal of your content or information does not ensure complete removal of that information from our website. For example, historical copies, or “caches,” may remain. 

Transmission of Information to Other Countries 

If you submit personal information to us your personal information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. By submitting your personal information to us you agree to the transfer, storage, and processing of your personal information in a country other than your country of residence including, but not necessarily limited to, the United States. 

Children's Privacy 

Our Services are not directed to children under the age of 13 and we do not knowingly collect personal information from children under the age of 13 on the website or through our mobile application. If we become aware that we have inadvertently received personal information from a visitor under the age of 13, we will delete the information from our records. 

Communicating With Us 

If you have any questions or comments about this Notice, or if you would like us to update information we have about you or your preferences, please contact us as indicated below: 

_______________ 

If we need, or are required, to contact you concerning any event that involves your personal information we may do so by e-mail, telephone, or mail. 

Changes To This Policy 

This privacy policy may be updated from time to time. Accordingly, you should check the date of this privacy policy (which appears at the top of this page) and review any changes since the last version. Your continued use of the website and/or mobile application following any modifications demonstrates your agreement to such changes. If at any time you do not agree to the terms of this policy, please do not use the website and our mobile application or provide us with personal information. 

Information for California Residents – California Privacy Rights 

California law requires us to disclose the following information with respect to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of the privacy policy. 

California Resident Rights Regarding Personal Information  

Capitalized terms in this “Notice to California Residents” section of the Notice shall have the meanings set forth in the California Consumer Privacy Act of 2018. Subject to certain limits under California law, California residents have a number of rights regarding their Personal Information. 

California residents have the right to request in writing, (i) a list of the categories of Personal Information, such as name, address, e–mail address, and the type of services provided to the customer, that we have disclosed to third parties (including Independent Affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties' direct marketing purposes, and (ii) the names and addresses of all such third parties. In addition, California residents have the right to request that we disclose to them (i) the categories of Personal Information we have collected about them, (ii) the categories of sources from which Personal Information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared Personal Information, and (v) the specific pieces of Personal Information we hold about an individual. 

California residents have the right to have their Personal Information deleted, unless the Personal Information is necessary for us or our service providers to: complete a transaction for which the Personal Information was collected, provide a good or service requested by the consumer or otherwise perform a contract between the business and the consumer; detect security incidents; protect against malicious, deceptive, fraudulent or illegal activity (or prosecute those responsible); debug to identify and repair functionality errors; exercise or ensure the right of another to exercise free speech or another legal right; comply with the California Electronic Communications Privacy Act, which compels the production of or access to electronic communication information or electronic device information with a search warrant; to enable solely internal uses aligned with the consumer's expectations given their relationship with the business; comply with a legal obligation; otherwise use the information internally in a lawful manner compatible with the context in which the consumer provided it. 

California residents have the right to opt-out of having their Personal Information sold. We do not sell the Personal Information of individuals we have actual knowledge are under the age of 13, unless we receive affirmative authorization from the consumer (if the consumer is between 13 and 16 years of age) or their guardian (if the consumer is under the age of 13). California residents may opt-out of the sharing of your Personal Information at any time by contacting us at _____________. You can find more detail about our practices in the “Personal Data Collected Through Automated Means” section above. California law may characterize our providing the following categories of information we share with companies that provide services to you or to us as "sales" of Personal Information:  

• Device and browsing information and other Internet activity information 
• Purchase or other commercial information 
• Geolocation information 
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) 

• Identifiers 

Californians can exercise their privacy rights by contacting us as specified in the Contact Us section below. 

Consumer Data Request 

We will handle requests under Applicable Law in California. When a request is made, we may verify your identity to protect your privacy and security. We will respond to written rights requests within 45 days following receipt at the link above. If we receive your request at a different e–mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are only required to respond to each customer twice per consecutive 12-month period. 

California Resident Personal Information Collected 

Our Services collect the following categories of Personal Information: Identifiers, Characteristics protected under state and federal law, Commercial information, Internet information, Geolocation data, and Inferences, for the operation of our services, auditing, security, internal research and development, and quality and safety business purposes, collected directly from individuals, as well as from service providers on our behalf. 

Customer Service collects the following categories of Personal Information: Identifiers, Characteristics protected under state and federal law, Commercial information, Internet information, and Geolocation data, for the operation of our services, auditing, security, and quality and safety business purposes, directly from individuals, as well as from service providers on our behalf. 

Sale of Personal Information and the Right to Opt-Out 

Though we do not receive any monetary compensation, our use of tracking technologies may be considered a “sale” under California law. Categories of personal information disclosed that may be considered a “sale” under California law: Basic Identifying Information, Device Information and Other Unique Identifiers, Internet or Other Network Activity, Geolocation Data, and Commercial Data. 

Categories of third parties to whom personal information was disclosed that may be considered a “sale” under California law: advertisers and marketing partners, data analytics providers, and social media networks. 

Non-Discrimination 

We do not discriminate against California residents who exercise any of their rights described in our privacy policy. 

Notice of Financial Incentive 

We may offer our customers a loyalty program that may provide rewards and exclusive offers only to members. We may also provide other programs, such as sweepstakes, contest, or other similar promotional campaigns (collectively, the “Customer Programs”). When you sign up for one of these Customer Programs, we typically ask you to provide information such as your name and contact information. Because our Customer Programs involve the collection of personal information, they might be interpreted as a “financial incentive” program under California law. The value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the applicable Customer Program, less the expense related to offering those products, services, and benefits to Customer Program participants.  

You may withdraw from participating in a Customer Program at any time by contacting us using the designated method set forth in the applicable Customer Program rules. Visit the terms and conditions page of each Customer Program to view full details, including how to join.