Vagaro Privacy Policy

This Privacy Policy describes how Vagaro Inc. and our subsidiaries and affiliated companies (collectively, “Vagaro,” “we,” or “us”) collect, use, disclose, and otherwise process information about you. This Privacy Policy applies to information we collect when you access or use our websites, mobile applications, devices, and other online products and services that link to this Privacy Policy (collectively, our “Services”) and when you otherwise interact with us, such as at events, through our customer support channels, or on social media. We may provide different or additional notices of our privacy practices for certain offerings, in which case those notices will supplement or replace the disclosures in this Privacy Policy.

Our Services are subject to either the Business Customer Terms of Service (“Business Services”), such as Vagaro Pro, or the Individual Customer Terms of Service (“Consumer Services”), such as our mobile applications. We provide Business Services to and on behalf of entities (“Businesses”), including sole proprietors and small, medium, and large businesses, that in turn may engage individuals to act on their behalf (“Representatives”), such as employees, contractors, and founders. We provide our Consumer Services directly to individuals for their own personal use (“Consumers”). Our relationship with you varies depending on which Services you access and use and how you interact with them.

For example, Businesses may contract with us as a service provider to provide Business Services to you on behalf of the Businesses, such as by managing their bookings through Vagaro Pro. This Privacy Policy does not apply to information about you that we collect and process when we act as a service provider. We process that information on behalf of those Businesses and only in accordance with their written instructions. The collection, use, retention, and deletion of that information is controlled by the Businesses and subject to their respective privacy policies. Please refer to the Businesses’ privacy policies for more information.

Except for California residents, this Privacy Policy also does not apply to information about you that we collect when you access or use our Services, or otherwise interact with us, as a Representative (i.e., in an employment or commercial context).

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice (such as by adding a statement to the Services or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

COLLECTION OF INFORMATION

The information we collect about you depends on how you interact with us. In this section, we describe the categories of information about you we collect and the sources of this information.

Information You Provide to Us

We collect information you provide directly to us as either a Consumer or Representative (for California residents only). For example, we collect information directly from you when you create an account, make a purchase, go through our identity or account verification process, fill out a form, answer a survey, submit or post content through the Services (including ratings, reviews, compliments, invitations, and other user-generated content you display as part of your account profile), communicate with us via third-party platforms, participate in a contest, sweepstakes, or promotion, sign up for rewards or marketing communications from us, request customer support, or otherwise communicate with us. The types of information that we collect directly from you include:

• Identifiers, including your contact information like name, email address, postal address, phone number, and signature;
• Demographic information, such as your birthdate and gender;
• Government identification numbers, such as your federal employer identification number, driver's license number, Social Security number, taxpayer identification number, or other government-issued identification number;
• Financial information, such as your payment card numbers. If you make a purchase from us, we work with a third-party payment processor to process your payment information;
• Professional or employment-related information, such as information about where you work and your title;
• Other information you provide to us, such as information in communications with us; images you upload to the Services; survey responses; information collected when you participate in contests, promotions, or other prospective seller marketing forms or devices; suggestions for improvements; or referrals.

Information We Collect Automatically

We automatically collect information about your interactions with us or our Services, including:

• Transaction Information, such as information about when and where payment transactions occur, the names of the transacting parties, a description of the transactions, the payment or transfer amounts, billing and shipping information, and the devices and payment methods used to complete the transactions;
• Contact list from your signed-in device(s), imported into your Vagaro account via the VagaroPro App upon your request and consent;
• Device, Usage, and Activity Information: We collect information about how you access our Services, including data about the device and network you use (such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version). We also collect information about your activity on our Services, including the route by which you access our Services, access dates and times, “log-in” and “log-out” information, browsing behavior (such as pages viewed and links clicked), search terms, and information about your activity on specific pages (such as mouse movements, keystrokes, and items placed in your cart or added to your wish list).
• Audio and Video Recordings, Photos, and Chat Content: We capture photographs and video recordings for security purposes, including during onboarding calls and on our premises. If you contact customer service through our chat feature or by phone, we may monitor and retain those conversations, including for training purposes.
• Precise Geolocation Information: With your consent, we may collect information about the precise location of your device. You may stop the collection of precise location information at any time (see the Your Choices section below for details).
• Information Collected by Cookies and Similar Tracking Technologies: We use tracking technologies, such as cookies, pixels, SDKs, and session replay, to collect information about your interactions with the Services and our marketing communications. These technologies help us improve our Services and marketing communications, personalize your experience, and analyze your interactions with us, including to see which areas and features of our Services are popular and count visits. They also allow us to recognize and alert you if you leave items in your shopping cart. For more information about the cookies and similar tracking technologies we use, and the choices available to you, see the Targeted Advertising and Analytics and the Your Choices sections below.

Information We Collect from Other Sources

We obtain information from other sources. For example, depending on the Services you access or use, we may collect information from identity verification, credit confirmation, and fraud detection providers, such as Plaid, financial institutions, such as Certegy, and mailing list providers.

We also use AI tools to gather publicly available information about Businesses or you for security and fraud prevention and to obtain background information that might be relevant to your use of our Services.

Additionally, if you create or log into your Vagaro account through a third-party platform (such as Amazon, Apple, Facebook, or Google), we will have access to certain information from that platform, such as your name, birthday, profile picture, username, and any other information the third-party platform discloses about you, in accordance with the authorization procedures determined by such platform.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address or infer that you are looking to purchase certain products or services based on your browsing behavior and past purchases.

USE OF INFORMATION

We use the information we collect to provide, maintain, and improve our products and services, (including the Services), which may include training and improving our models that power AI features of our Services.

We also use the information we collect to:

• Process payments, process and fulfill your orders, and facilitate service requests;
• Develop new products and services;
• Display your historical transaction or appointment information;
• Process or record payment transactions or money transfers;
• Personalize your experience with us;
• Send you technical notices, security alerts, support messages, and other transactional or relationship messages;
• Send you marketing communications (see the Your Choices section below for information about how to opt out of these communications at any time);
• Monitor and analyze trends, usage, and activities in connection with our products and services;
• Target advertisements to you on third-party platforms and websites (for more information and to opt out, see the Targeted Advertising and Analytics section below);
• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
• De-identify or aggregate the information so that it can no longer be used to infer information about or otherwise be linked to you. We maintain and use this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law;
• Detect, investigate, respond to, prosecute, and help protect against security incidents and other malicious, deceptive, fraudulent, or unlawful activity, and help protect the rights and property of Vagaro and others; and
• Comply with our legal and financial obligations.

TARGETED ADVERTISING AND ANALYTICS

We engage others to provide analytics services, serve advertisements, and perform related services across the web and in mobile applications. To do this, Vagaro and these partners may use cookies, pixels, SDKs, and similar technologies to collect information about your use of our Services and other websites and mobile apps, including your device identifiers, IP address, web browser and mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, order information, items added to cart, and conversion information. This information is used to deliver advertising targeted to you on other companies’ websites and mobile apps, understand the effectiveness of this advertising, analyze and track data, determine the popularity of certain content, and better understand your activity. Depending on where you reside, you can opt out of ad targeting through cookies and similar technologies on our website by following the prompts behind the Your Privacy Choices link in the site footer. Your opt-out choice will be linked to your browser only; therefore, you will need to renew your opt-out choice if you visit our website from a new device or browser, or if you clear your browser’s cookies. You can opt out of these activities on your mobile device by navigating to your device application settings and toggling off tracking.

In addition to ad targeting activities that rely on cookies and similar technologies, we work with advertising partners to translate other identifiers, such as your email address or phone number, into a unique identifier (called a hashed value) that such partners can then use to show ads that promote Vagaro. Depending on where you reside, you may opt out of these disclosures by filling out our web form located here.

The activities described in this section may constitute “targeted advertising,” “sharing,” or “selling” under certain privacy laws. See the Additional Information for Specific Jurisdictions section below for details.

You can also learn more about interest-based ads, or opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices or www.youronlinechoices.eu (if you reside in Europe). Your device may also include a feature that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes.

DISCLOSURE OF INFORMATION

We disclose information about you as described in this Privacy Policy and in the following ways:

• Vendors and Service Providers. We make information about you available to our vendors, service providers, contractors and consultants who perform services on our behalf, such as companies that assist us with web hosting, shipping and delivery, payment processing, financing, fraud prevention, identity verification, fee collection, customer service, analytics, marketing, and running contests, special offers, or other events or activities.
• Financial Institutions. We make information about you available to certain financial institutions when you sign up and use certain of our Services, like our buy now, pay later services provided by Certegy.
• The Public. If you provide a product review or otherwise post content on our Services, the public will be able to see this information.
• Law Enforcement Authorities and Individuals Involved in Legal Proceedings. We disclose personal information in response to a request for information if we believe that disclosure is in accordance with, or required by, any applicable law, regulation, or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
• To Protect the Rights of Vagaro and Others. We may disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Vagaro, our users, the public, or others.
• Professional Advisors. We disclose personal information to our legal, financial, insurance, and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• Corporate Transactions. We disclose personal information in connection with, or during negotiations of, certain corporate transactions, including a merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Corporate Affiliates. Personal information is disclosed between and among Vagaro and our parents, affiliates, subsidiaries, and other companies under common control and ownership.
• With Your Consent or at Your Direction. We make personal information available to third parties when we have your consent or you intentionally direct us to do so.

We also disclose aggregated or de-identified information that cannot reasonably be used to identify you.

DATA RETENTION

We store personal information associated with your account for as long as your account remains active. We store other personal information for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Privacy Policy.

YOUR CHOICES

Account Information

You can access, correct, and delete certain information stored within your Vagaro account at any time by filling out our web form located in the website footer.

Precise Location Information

When you first launch any of our mobile apps that collect precise location information, you will be asked to consent to the app’s collection of this information. If you initially consent to our collection of such location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device.

Cookies and Similar Tracking Technologies

Vagaro uses cookies and similar tracking technologies, as described above. You can usually adjust your browser settings to remove or reject browser cookies. You can also adjust certain cookie settings by clicking Cookie Preferences in the website footer. Please note that removing or rejecting cookies could affect some of the functionality of our Services.

Communications Preferences You may opt out of receiving text messages or promotional emails from Vagaro by following the instructions in those communications or by, for promotional emails, by logging into your Vagaro account and changing your notification settings. If you opt out, we may still send you non-promotional emails, such as those about your account or orders.

Mobile Push Notifications

With your permission, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

ADDITIONAL INFORMATION FOR SPECIFIC JURISDICTIONS

Individuals Residing in Certain U.S. States

Some U.S. states have enacted privacy laws that grant their residents certain rights and require specific disclosures (“State Privacy Laws”). If you reside in California, Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tenneessee, Texas, Utah, or Virginia, this section applies to you. This section also serves as our California notice at collection.

Additional Disclosures

Our Privacy Policy explains how we collect, use, and disclose information about you, as well as our targeted advertising and analytics practices. As required by certain State Privacy Laws, we use the tables below to explain this same information.

Use and Disclosure of Personal Information for Business Purposes

We collect information that is considered “sensitive” under State Privacy Laws but we do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.

As described in the Collection of Information section above, we collect personal information from various sources, including directly from you, automatically when you access or use our Services, and from third-party sources.

We retain personal information as described above.

Sales, Sharing, and Targeted Advertising Activities

We also disclose certain categories of personal information to show you targeted ads on third-party properties, expand the reach and effectiveness of our own marketing campaigns, and allow certain third parties to use this information for their own marketing purposes. These disclosures may be considered “sales,” “sharing,” or use of personal information for “targeted advertising” under State Privacy Laws, and the table below provides more information about our practices.

We do not engage in sales, sharing, or targeted advertising using personal information about consumers we know to be under the age of 16, or higher age where required by law.

Your Rights under State Privacy Laws

Opt Out of Sales, Sharing, and Targeted Advertising

You may opt out of activities that we engage in that constitute “targeted advertising,” “sharing,” or “sales” of personal information under the State Privacy Laws by:

• Cookies and Similar Technologies: Following the prompts behind the Your Privacy Choices link in the footer of our websites. Your opt-out choice will be linked to your browser only; therefore, you will need to renew your opt-out choice if you visit our website from a new device or browser, or if you clear your browser’s cookies. From within our mobile app, you can opt out by navigating to your device application settings and toggling off tracking.

You can also opt out by visiting our websites with a legally recognized universal opt-out signal enabled, such as the Global Privacy Control. If you are not logged into your account with us, our processing of the signal will be limited to cookie-based sales, sharing, and targeted advertising for the specific browser or device that you are using.

Access, Correction, and Deletion

You have the right to (1) request to know more about and access your personal information, including in a portable format, (2) request deletion of your personal information, and (3) request correction of inaccurate personal information.

To request access, correction, or deletion of your personal information, please submit your request to support@vagaro.com or call our toll-free number at 1-800-919-0157.

Nondiscrimination

You have the right not to be discriminated against for exercising any of your privacy rights.

Appeals

If we deny your request, you may appeal our decision by contacting us at legal@vagaro.com. If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.

Authorized Agents

If you are an authorized agent seeking to make a request to opt out of sales, sharing, or targeted advertising on behalf of a consumer, please contact us at support@vagaro.com with a subject line "Data Subject Request - Agent Request" and someone will be in touch with the agent and you to verify the request. We will try to comply with your request as soon as reasonably practicable and meet statutory timelines.

If you reside in California, you may also designate an authorized agent to submit an access, deletion, or correction request on your behalf. We may ask authorized agents to submit proof of their authority to make a request, such as a valid power of attorney or proof that they have signed permission from the consumer who is the subject of the request. In some cases, we may contact the individual who is the subject of the request to verify their own identity or confirm the authorized agent has permission to submit the request. If you are an authorized agent seeking to make an access, correction, or deletion request on behalf of a California resident, please contact us at support@vagaro.com with a subject line "Data Subject Request - Agent Request" and someone will be in touch with the agent and you to verify the request. We will try to comply with your request as soon as reasonably practicable and meet statutory timelines.

International Transfers

Vagaro is based in the United States, and we and our service providers process and store personal information on servers located in the United States and other countries. Whenever we make restricted international transfers of personal information, we take steps to ensure that your personal information receives an adequate level of protection (by putting in place appropriate safeguards) or ensure that we can rely on an appropriate derogation under data protection laws.

Individuals in Europe

If you are located in Europe, this section applies to you.

Legal Basis for Processing

When we process your personal data as described in this Privacy Policy, we do so in reliance on the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested);
• When we have a legitimate interest in processing your personal information to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you);
• To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications); or
• When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing of your personal information, you may withdraw such consent at any time.

Data Subject Requests

You have the right to (1) access your personal data, including in a portable format, (2) request erasure of your personal data, and (3) request correction of inaccurate personal data. In addition, you may have the right to object to certain processing or request we restrict certain processing. To exercise any of these rights, please visit here submit a request to support@vagaro.com or call our toll-free number at 1-800-919-0157.

If you have a concern about our processing of personal data, we encourage you to contact us in the first instance by email to support@vagaro.com. However, if we are not able to resolve it, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the European Union: https://edpb.europa.eu/about-edpb/board/members_en
For individuals in the UK: https://ico.org.uk/global/contact-us/
For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.

Individuals in Canada

If you are a Canadian resident, this section applies to you.

Consent

By submitting personal information to Vagaro, our service providers, or our agents, you consent to the collection, use, disclosure, and transfer of your personal information in accordance with this Privacy Policy and as permitted or required by law.

You may withdraw your consent at any time to the collection, use, disclosure, or transfer of your personal information by contacting Vagaro as set forth in the Contact Us section below. If you withdraw your consent (or if you decide not to provide certain personal information), you acknowledge that Vagaro may not be able to provide you, or continue to provide you, with certain products, services, or information that may be of value to you.

Canada’s Anti Spam Law

Vagaro will only send you commercial electronic messages (“CEMs”) where we have your express or implied consent to do so. Your consent to receive CEMs is implied where we have an existing business relationship with you, or you have reached out to us and made an inquiry within a certain time frame. You may unsubscribe from receiving CEMs at any time, by clicking the unsubscribe button on an email. If you opt out, we may still send you non-promotional messages, such as those about your account or our ongoing business relations.

CONTACT US

If you have questions about this Privacy Policy, please contact us at:

Vagaro Inc., 4430 Rosewood Drive, Suite 500. Pleasanton, CA 94588 USA

support@vagaro.com or toll free at 1-800-919-0157.