In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide us when you register on the Services, express an interest in obtaining information about us or our products and Services when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information we collect depends on the context of your interactions with us and the Services, your choices, and the products and features you use. The personal information we collect may include the following:

• Full Name: Helps in personalizing the user experience and for administrative purposes.

• Email Addresses: Essential for communication, marketing, and account-related notifications.

• Transaction History: Purchases, service usage, returns, and more.

• Payment Information: Credit/debit card details, bank information, or other payment methods.

• Mailing Addresses: Necessary for shipping or billing purposes.

• IP Address: Can be used for security purposes and location-specific functionalities.

• Device Information: Type of device, operating system, and other software/hardware details.

• Browser Data: Type of browser used, version, and settings.

• Usage Data: Pages visited, features used, time spent, click patterns. 

• Communication Preferences: Whether the user has opted for newsletters, marketing emails, etc. 

• Product and Service Preferences: Previous purchases, viewed products, wish list items, etc. 

• Reviews and Ratings: Feedback provided for products or services.

• Form Submissions

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and the security code associated with your payment instrument. Stripe stores all payment data. You may find their privacy notice link(s) here: https://stripe.com/privacy.

Hosting and Data Storage: Our website is hosted on Squarespace. They provide us with an online platform to offer our services and products to you. Your data may be stored through Squarespace’s data storage, databases, and general Squarespace applications. They store your data on secure servers behind a firewall. You may find their privacy notice link(s) here: https://www.squarespace.com/privacy.

All personal information you provide must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information is automatically collected.

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information). Still, it may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical details. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.

 Like many businesses, we also collect information through cookies and similar technologies. 

The information we collect includes:

• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this data may include your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

• Location Data. We collect location data, such as information about your device's location, which can be precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you opt-out, you may not be able to use certain aspects of the Services.

In Short: We process your information to provide, improve, and administer our Services, communicate with you for security and fraud prevention, and comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for various reasons, depending on how you interact with our Services, including:

• To Provide and Maintain Our Services:

• Fulfilling service requests, managing transactions, and processing payments.

• Offering customer support and responding to queries or feedback.

• Administering account profiles and personalizing user experiences.

• To Improvement and Development: 

• Monitoring and analyzing trends and usage to enhance our existing products and services.

• Developing new features, products, or functionalities based on user feedback and preferences.

• Conducting surveys and collecting feedback

• For Communication:

• Sending you updates, security alerts, technical notices, and administrative messages.

• Delivering promotional messages, newsletters, or marketing communications.

• Offering information about products, services, promotions, and events that might interest you. 

• For Safety and Security:

• Protecting our platform against security breaches and protecting our users against fraud or illegal activities.

• Using information to verify accounts and activity, monitor suspicious or fraudulent activity, and identify violations of our policies.

• To Comply with Legal Obligations:

  • Responding to lawful requests and legal processes.

  • Enforcing our terms, privacy policies, and agreements.

  • Protecting the rights and property of Hailey Group, our agents, customers, and others.

• With Your Consent:

  • For any other purpose disclosed to you related to a specific service.

  • For any uses for which we have your explicit permission.

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

This section applies to you if you are in the EU or UK.

 The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. As such, we may depend on the following legal grounds to process your personal information:

• Consent. We may process your information if you have permitted us (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent by emailing us at dabney@haileygroup.com at any time.

• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request before entering into a contract with you.

• Legal Obligations. We may process your information where we believe it is necessary to comply with our legal obligations, such as cooperating with a law enforcement body or regulatory agency, exercising or defending our legal rights, or disclosing your information as evidence in litigation in which we are involved.

• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person.

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

We may process your information if you have given us specific permission (i.e., express consent) to use your data for a specific purpose or in situations where your authorization can be inferred (i.e., implied consent). You can withdraw your consent by emailing us at dabney@haileygroup.com at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

• For investigations, fraud detection, and prevention

• For business transactions, provided certain conditions are met.

• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.

• For identifying injured, ill, or deceased persons and communicating with next of kin

• If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse.

• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information, the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.

• If an individual produced it during their employment, business, or profession, the collection is consistent with the purposes for which the information was produced.

• If the collection is solely for journalistic, artistic, or literary purposes.

• If the information is publicly available and is specified by the regulations

In Short: We may share information in specific situations described in this section and/or with the following third parties. 

We may need to share your personal information in the following situations:

• Business Transfers:

In the event of a restructuring, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), we may transfer the personal information we have collected to the relevant third party. You will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information and any choices you may have regarding your personal information.

• Business Partners:

We occasionally collaborate with other companies to offer joint promotions or products. If you purchase or specifically express interest in a jointly offered product, service, or promotion, we may share relevant personal data (like name and email address) with those partner(s). This shared data allows us and our partners to provide information about products or services we believe you will find of interest. Our partners must protect the confidentiality of the data we share with them and use it only to offer the jointly offered product or service.

• Legal Obligations and Security:

We may also disclose your personal information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or to respond to requests from public and government authorities, (ii) protect and defend our rights or property, (iii) act in urgent circumstances to protect the personal safety of users of the website or the public, or (iv) protect against legal liability.

• Third-Party Service Providers:

We may employ third-party companies and individuals to facilitate our service, provide service on our behalf, perform website-related services, or assist us in analyzing how our website is used. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

• Consent:

There may be other times when we collect and use personal information, for instance, when someone submits feedback or queries. We will then inform you about the purpose for which we have collected the data and seek your consent where required.

It's important to note that the website may contain links to other external websites and third parties. Once you use these links, you leave our site, and we cannot be responsible for the protection and privacy of any information you provide on other websites. Always exercise caution and refer to the privacy statement of the website in question.

In Short: We may use cookies and other tracking technologies to collect and store your information.

Our website, hosted on Squarespace, uses cookies and similar technologies to improve user experience, and they might place cookies on your device. For further details on how Squarespace uses cookies, you can refer to Squarespace's cookie policy on their website.

In Short: At Hailey Group, we prioritize the safety and security of your personal information. We have implemented various measures to protect your data from unauthorized access, use, and disclosure. Some of our security procedures include:

• Encryption: We use encryption to protect sensitive data transmitted online. Our website is SSL-certified, ensuring that any information you provide online is encrypted and transmitted securel

• Access Control: Only authorized employees have access to personal data and are trained to handle such information with utmost confidentiality.

• Regular Audits: We routinely review our security and privacy practices to ensure they are up-to-date and effective.

• Third-party Platforms: As our website is hosted on Squarespace, it's also essential to note their security measures. Squarespace employs robust security measures to protect against unauthorized access, alteration, disclosure, or data destruction. Their protective measures include internal reviews of data collection, storage, and processing practices. They also utilize technical and physical security defenses to guard against unauthorized access to the systems where they store personal data.

We are committed to ensuring the ongoing safety of your data and are constantly exploring new avenues to enhance our security protocols. However, while we strive to protect your personal information, no method of transmission over the Internet or method of electronic storage is 100% secure, so we cannot guarantee its absolute security.

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a more extended retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will need us to keep your personal information for longer than the period users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

In Short: We do not knowingly collect data from or market to children under 18 years of age.

 We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to delete such data from our records promptly. If you become aware of any data we may have collected from children under the age of 18, please get in touch with us at dabney@haileygroup.com.

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

You have certain rights under applicable data protection laws in some regions (like the EEA, UK, Switzerland, and Canada). These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, (iv), if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to processing your personal information. You can request by contacting us using the contact details in the “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" section below.

We will consider and act upon any request by applicable data protection laws.

Suppose you are located in the EEA or UK, and you believe we are unlawfully processing your personal information. In that case, you also have the right to complain to your Member State or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent, depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent anytime by contacting us using the contact details provided in the “HOW CAN YOU CONTACT US ABOUT THIS NOTICE section" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can

• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some data in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, and/or comply with applicable legal requirements. 

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove cookies and reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. 

If you have questions or comments about your privacy rights, you may email us at Dabney Hailey.

Most web browsers, mobile operating systems, and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference and not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

In Short: If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you are granted specific rights regarding access to your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A - As long as the user has an account with us.

• Category B - As long as the user has an account with us.

• Category G - As long as the user has an account with us.

  
  

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels.

• Participation in customer surveys or contests; and

• Facilitation in the delivery of our Services and responding to your inquiries.

• 
  

How do we use and share your personal information?

Learn how we use your personal information in the "HOW DO WE PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers under a written contract between us and each service provider. Learn more about how we disclose personal information in the section "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for business purposes, such as undertaking internal research for technological development and demonstration. This is not considered the "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal data belonging to website visitors, users, and other consumers in the future.

California Residents

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal data (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request the removal of unwanted data that you publicly post on the Services. To request removal of such data, please get in touch with us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

This section applies only to California residents. You have the rights listed below under the California Consumer Privacy Act (CCPA).

The California Code of Regulations defines a "resident" as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

Your rights concerning your personal data.

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. Suppose you ask us to delete your personal data. In that case, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know.

 Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;

• the categories of personal information that we collect;

• the purposes for which the collected personal information is used;

• whether we sell or share personal information to third parties;

• the categories of personal information that we sold, shared, or disclosed for a business purpose;

• the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;

• the business or commercial purpose for collecting, selling, or sharing personal information; and

• the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights,

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumers’ sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person with whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use the personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for verification. However, we cannot verify your identity from the information we have maintained. In that case, we may request that you provide additional information to verify your identity and for security or fraud prevention purposes. We will delete such other information as soon as we finish verifying you.

Other privacy rights

• You may object to the processing of your personal information.

• You may request correction of your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the information.

• You can designate an authorized agent to request the CCPA on your behalf. We may deny a request from an authorized agent who does not submit proof that they have been validly authorized to act on your behalf by the CCPA.

• You may request to opt out of future selling or sharing of your personal information with third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the request submission date.

To exercise these rights, you can contact us by submitting a data subject access request, by email at dabney@haileygroup.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

Colorado Residents

This section applies only to Colorado residents. You have the rights listed below under the Colorado Privacy Act (CPA). However, these rights are not absolute; in some instances, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data.

• Right to access your personal data.

• Right to correct inaccuracies in your personal data.

• Right to request deletion of your personal data.

• Right to obtain a copy of the personal data you previously shared with us.

• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

To submit a request to exercise the above rights, please dabney@haileygroup.com or submit a data subject access request.

If we decline to take action regarding your request and you wish to appeal our decision, please email us at dabney@haileygroup.com. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Connecticut Residents

This section applies only to Connecticut residents. You have the rights listed below under the Connecticut Data Privacy Act (CTDPA). However, these rights are not absolute; in certain cases, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data.

• Right to access your personal data.

• Right to correct inaccuracies in your personal data.

• Right to request deletion of your personal data.

• Right to obtain a copy of the personal data you previously shared with us.

• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

To submit a request to exercise these rights described above, please email dabney@haileygroup.com or submit a data subject access request.

 If we decline to take action regarding your request and you wish to appeal our decision, please email us at dabney@haileygroup.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Utah Residents

This section applies only to Utah residents. You have the rights listed below under the Utah Consumer Privacy Act (UCPA). However, these rights are not absolute; in some instances, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data.

• Right to access your personal data.

• Right to request deletion of your personal data.

• Right to obtain a copy of the personal data you previously shared with us.

• Right to opt out of processing your personal data if it is used for targeted advertising or the sale of personal data.

To submit a request to exercise these rights described above, please email dabney@haileygroup.com or submit a data subject access request.

Virginia Residents
Under the Virginia Consumer Data Protection Act (VCDPA):

"Consumer" means a natural person who resides in the Commonwealth and acts only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

"Personal data" means any information linked or reasonably linkable to an identifiable natural person. "Personal data" does not include de-identified data or publicly available information.

"Sale of personal data" means exchanging personal data for monetary consideration.

If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.

Your rights concerning your personal data:

• Right to be informed whether or not we are processing your personal data.

• Right to access your personal data.

• Right to correct inaccuracies in your personal data.

• Right to request deletion of your personal data.

• Right to obtain a copy of the personal data you previously shared with us.

• Right to opt out of processing your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling").

Exercise your rights provided under the Virginia VCDPA.

You may contact us by email at dabney@haileygroup.com or submit a data subject access request.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify your and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period and the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and its reasoning. If you wish to appeal our decision, please email us at dabney@haileygroup.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. You may contact the Attorney General to submit a complaint if your request is denied.

In Short: Yes, we will update this notice to comply with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

If you have questions or comments about this notice, you may email us at dabney@haileygroup.com or contact us by post at:

Hailey Group

__________

Cambridge, MA

United States

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.