Effective date: 05/17/22
Underlining, Inc. and its affiliated entities and brands, including TatBrow®, Hide®, and Nailboo® (“Underlining,” “we,” or “us”) are committed to respecting your privacy and protecting your personal information, whether you are a customer, potential customer, or other user of our web services (collectively, “you”). This Privacy Policy explains the types of personal information we may collect from visitors to our websites, including www.underlining.com, www.nailboo.com, www.hide.shop, www.freewillhair.com, and www.tatbrow.com and all related websites, mobile apps, and web-based services (our “Sites”). This Policy also describes how we use personal information, the purpose for sharing and recipients of personal information, and your available rights and choices associated with that information.
This Privacy Policy is provided in a layered format. You can jump to a specific section by clicking on the section below:
1. Collection of personal information. We collect certain personal information about you when you sign up for an account or otherwise use our websites. We may also automatically collect information regarding your use of our sites as you use them.
2. Use of personal information. We use your personal information for various purposes connected with your interest in our websites, products, and services, and to allow us to maintain and improve them.
3. Sharing of Personal Information. We may share your personal information with certain third parties, such as with our service providers and to provide you with opportunities that we believe may be of interest to you.
4. Your rights and choices. You may have certain rights and choices regarding our collection, use, and disclosure of your personal information.
5. Data security. The security of your personal information is of utmost important to us and we maintain appropriate safeguards to protect it.
6. Cookie policy. When you visit our websites, we may collect certain information from you automatically through cookies and other tracking technologies.
7. Children's privacy. You must be at least 18 years old or older to register to use our sites.
8. International data transfers. Our websites are operated exclusively in the United States.
9. California Privacy Notice. We provide additional disclosures and rights to California residents.
10. European Privacy Notice. We provide additional disclosures and rights to individuals located in Europe.
11. Links to other websites. Our websites may contain links to other websites that are not operated by us and that are subject to third party privacy policies and other terms.
12. Changes to this Privacy Policy. We may change this Privacy Policy from time to time to reflect new services or changes in our data practices or relevant laws.
13. Contact us. You may contact us for comments or questions in various ways.
This Privacy Policy does not apply to third-party websites, products or services, even if they may link to our Sites or our Sites may link to them. We recommend you review the privacy practices of those third parties before connecting accessing third party websites and sharing any personal information.
We also encourage you to review our Terms of Use to understand how your personal information will be treated as you make full use of our Sites. Unless otherwise defined in this Privacy Policy, capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Use.
1. Collection of Personal Information
For purposes of this Privacy Policy, “personal information” means any information that relates to an identified or identifiable individual. The personal information we collect through our Sites will be apparent by the context of the page, and may include but is not limited to the types of information described below.
a. Personal information you provide us
We may collect the following personal information about you that you choose to provide us when you use our Sites:
b. Information that we automatically collect
Our Sites use cookies and other tracking technologies such as web beacons, embedded scripts, and tags (“Cookies”), which collect information from you automatically as your use our Sites, including:
We also collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services. For example, some of our community websites may use Google Analytics on our Sites to help us analyze your use of our Sites and diagnose technical issues.
Please review our Cookie Policy below for more information about our use of these technologies.
c. Aggregated, anonymized, and deidentified information
We may create aggregated, anonymous or de-identified data from personal information by removing data components that make the data personally identifiable to you or through obfuscation or other means. Our use of aggregated, anonymized and de-identified data is not subject to this Privacy Policy.
2. Use of Personal Information
We may use the personal information that we collect about you in the following ways:
a. Our products and services
We use the personal information we collect to provide the products and services that Underlining offers to its customers, as well as to provide, maintain, and improve our Sites and the services that Underlining offers through them (together, our “Products and Services”). This includes:
b. Digital marketing communications
We may send you promotional email communications about Underlining, invite you to participate in events or promotions, or otherwise communicate with you for marketing purposes, consistent with your preferences and applicable law. For example, when you provide your email address to join our email newsletter, or when we otherwise collect your contact information through your interaction with our Sites, we may use that information to follow up with you regarding an event or send you information that you have requested about Underlining or our third party partners. You may opt out of receiving any, or all, of these marketing communications from us via the unsubscribe link provided in such emails or by following further instructions provided in Your Rights and Choices.
3. Sharing of Personal Information
We may share your personal information with the following categories of third parties:
a. Among our brands and affiliates. We may share personal information among our various brands and affiliates to provide our Sites, provide the Products and Services, and for internal administrative purposes.
b. Our service providers. We share personal information with our service providers to provide services on our behalf, such as payment processing, analytics, advertising, hosting, marketing, customer and technical support, and other services. 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 the information for any other purpose.
c. Third-party platform advertising. We may share your information with third-party platform providers who assist us in serving advertising regarding the Sites, Products, and Services to others who may be interested. We also partner with third parties (such as Facebook and Google) who use Cookies to serve interest-based advertising and content on their respective third-party platforms that may be based on your preferences, location and/or interests.
d. Affiliate and business transfer. If Underlining, including any of its brands or affiliates, is involved in a merger, acquisition, asset sale, or other corporate combination, your personal information may be transferred to the acquiring or surviving entity. If such transfer results in a material change to the use of your personal information, we will provide notice before your personal information is transferred and/or becomes subject to a different privacy policy
e. Compliance and harm prevention. We may share personal information as we believe necessary (i) to comply with applicable law, rules and regulations; (ii) to enforce our contractual rights; (iii) to investigate possible wrongdoing in connection with the Sites, Products, and Services; (iv) to protect and defend the rights, privacy, safety and property of Underlining, you, and others; and (v) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.
4. Your Rights and Choices
You may have rights and choices regarding our use and disclosure of your personal information. Unless instructed otherwise, you can exercise these rights and choices using the information in the Contact Us section at the end of this Policy.
a. Opting out of receiving electronic communications from us. If you no longer wish to receive promotional email communications from us, you may opt out via the unsubscribe link included in such emails. We will comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required in order to provide you with our Products and Services or for other reasons disclosed in this Policy.
b. Your California privacy rights. California residents have certain rights with respect to our collection, use, and sharing of their personal information. Please review our California Privacy Notice for more information about those rights.
c. Your Nevada privacy rights. Nevada residents have the right to request to opt out of any “sale” of their personal information. Underlining does not sell your personal information. However, you may nonetheless request to opt out of the future sale of your personal information. If you are a Nevada resident and would like to make such a request, please contact us using the information in the Contact Us section at the end of this Policy, and provide “Nevada Privacy Rights” in the subject line. You must include your full name, email address and postal address in your request so that we can verify your Nevada residence and respond. In the event we sell your personal information after the receipt of your request, we will make reasonable efforts to comply with such request.
d. Your European privacy rights. Individuals located in the European Economic Area, United Kingdom, and Switzerland have certain rights with respect to our collection, use, and sharing of their personal information. Please review our European Privacy Notice for more information about those rights
5. Data Security
The security of your personal information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we use reasonable practices and procedures to protect your personal information, we cannot guarantee its absolute security. We maintain appropriate technical, administrative and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, disclosure or misuse.
6. Cookie Policy
When you visit our Sites, we may collect information from you automatically through Cookies. We also rely on partners to provide many features of our Sites using data about your use of the Sites. We use Cookies for the following purposes:
You can modify your browser settings to decline or accept Cookies. However, in a few cases, some of our Sites’ features may not function as designed.
If you wish to opt out of our sharing of the data that is gathered when you visit our Site for purposes of targeted digital advertising, we encourage you to visit the Network Advertising Initiative or the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising for more information about opting out of seeing targeted digital advertisements. You may also visit these websites for more information on how you can opt back in to the sharing of data.
Opting out of advertising networks does not necessarily mean that you will not receive advertisements while using our Sites or on other websites.
We do not support Do Not Track functionality. 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.
This website uses cookies to help keep track of items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via SMS.
7. Children’s Privacy
You must be at least 18 years old or older to register use our Sites and the Products and Services offered through them. The Sites are intended for a general audience and we do not knowingly collect personal information from children under age 18 through the Sites.
If you are a parent or guardian and you are aware that a child under age 13 has provided us with personal information without parental consent, please contact us using the information in the Contact Us section. If we become aware that we have collected personal information from children under age 13 without verification of parental consent, we will take steps to remove that information from our servers.
8. International Data Transfers
Our Sites are operated exclusively in the United States. We may transfer, store and use information we collect and maintain about you, including personal information outside of your state, province, country or other governmental jurisdiction. The data protection laws in the jurisdiction in which we process personal information may differ from those of your jurisdiction, and in certain circumstances, your personal information may be subject to access requests from governments, courts, law enforcement agencies or regulatory agencies in those other jurisdictions. By using the Sites or providing us with any information, you consent to the transfer and processing of your information, including personal information, in the United States as set forth in this Privacy Policy.
If you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, we comply with any applicable laws to provide an adequate level of data protection to the U.S., as described further in European Privacy Notice. Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use EU Standard Contractual Clauses with data recipients located outside the EEA or the UK as well as other appropriate measures and safeguards.
9. Your California Privacy Rights
This Section of the Privacy Policy applies to any California residents about whom we collect Personal Information (“Consumers”). The provisions contained within this section are intended to provide notices in compliance with the California Consumer Privacy Act of 2018 (“CCPA”). Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy.
The CCPA provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of personal information, as well as rights to access, delete, and restrict the sale of certain personal information we collect about them. California residents also have the right not to receive discriminatory treatment by us for the exercise of your privacy rights under the CCPA. If you are a California resident, you may submit a request to exercise these rights by completing our online webform or by emailing us using the information provided in the Your Privacy Rights section below.
If you are a visually-impaired customer, a customer who has another disability or a customer who seek support in other language, you may access this California Privacy Notice by emailing us at support@underlining.com.
a. Personal Information We Collect
For the purposes of this California Privacy Notice, except where a different definition is noted, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household. Personal information does not include publicly available information, information that has been de-identified or aggregated, or other information covered by certain sector-specific privacy laws.
Underlining collects Personal Information provided by Consumers through the Site. Over the last twelve (12) months, we have collected the following categories of personal information from Consumers:
b. What We Do With Your Personal Information
Underlining may collect, use, or disclose personal information about you for the purposes detailed in Section 2 of our Privacy Policy.
c. Sources of Collected Personal Information
We may collect personal information from the following categories of sources:
We may supplement the information described above with information we obtain from other sources, including from both online and offline data providers.
d. Who We Share Personal Information With
We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes.
We do not sell your personal information to third parties, including personal information of minors under 16 years of age. However, as with nearly every e-commerce company, we do share a limited set of data that is gathered when you visit our Site, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements. To the extent this activity is interpreted as included in California’s broad definition of “data sale,” we have provided you with opt-out rights as to that activity as described in subsections (e) and (f) below.
The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.
e. Your Privacy Rights
If you are a California resident, you have the following rights under applicable California law in relation to your personal information, subject to certain exceptions:
How to submit a request. You may exercise any of the rights described in this section by emailing us at privacy@underlining.com or post mail at: Underlining, Inc., 1065 SW 8th St, PMB 668, Miami, FL 33130.
Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”) as permitted by the CCPA. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the personal information on. In order to verify you, you must provide us with your first and last name and email address. These rights are also subject to various exclusions and exceptions under applicable laws.
You may also designate an authorized agent, in writing or through a power of attorney, to request to exercise the above rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing the letter of authorization or power of attorney to privacy@underlining.com.
We currently do not collect household data. If we receive a Right to Know or Right to Delete request submitted by all members of a household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of 13, as we do not collect personal information from any person under the age of 13.
We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days.
Direct marketing by third parties. We do not disclose this type of personal information to third parties for their own purposes, and we permit you to opt-out of any disclosures of non-identifiable personal information. However, because California residents have the right to request information regarding such practices under California’s “Shine the Light” Law, please contact us using the information provided at the end of this Policy. You must include your full name, email address and postal address in your email or mail request so that we can verify your California residence and respond. “Personal information” under this California law means any information that identified, described, or was able to be associated with an individual at the time of disclosure.
We will continue to update our business practices as direct regulatory guidance becomes available. For more information on interest-based advertising, please review the information we have provided elsewhere in this Privacy Policy, including in our Cookie Policy.
f. Notice of Right to Opt-Out
As noted in Sections D and E above, we do not currently sell any personal information. We do, however, participate in behavioral advertising networks. To the extent participation in such networks is deemed to be a data sale under the CCPA, we encourage you to visit the Network Advertising Initiative and/or the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising for more information about opting out of seeing targeted digital advertisements.
When you visit our website, log in, register or open an email, cookies, ad beacons, and similar technologies may be used by our online data partners or vendors to associate these activities with information they or others have about you, including your email address. We (or service providers on our behalf) may then send communications and marketing to these email addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.
Notwithstanding anything else in this policy, we and/or our partners may use pixels and pixel tags, and place, read or use cookies the collect information from your device and/or Internet browser. These cookies do not contain personally identifiable information, however, it may be possible for our third-party business partners to combine it with other information in order to identify your email address or other personally identifiable information about you. For example, the cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us, e.g., your email address, which we may share with a data provider solely in hashed, non-human readable form. By using our Service, you agree that us and our third-party partners may store, sell, port, combine with other data, monetize, utilize and otherwise use either (i) the personally indefinable information about you that we share with them, or (ii) the personally identifiable information they discover and/or identify as described above. Visitors can also express their choices for display advertising, through the following platforms: Digital Advertising Alliance opt-out platform or the Network Advertising Initiative opt-out platform. We and/or our partners may also use cookies for delivering personalized advertising emails. These cookies are used to identify the visitors of our advertisers’ websites and send personalized emails based on the visitors’ browsing experience. We and/or our partners use cookies, pixels and other tracking technology to associate certain Internet-related information about you, such as your Internet Protocol address and what Web browser you are using, with certain of your online behaviors, such as opening emails or browsing websites. Such information is used to customize ads or content and may be shared with our partners.
g. How to Contact Us
If you have any questions about this California Privacy Notice or wish to exercise one of the privacy rights detailed above, please submit a rights request or otherwise contact us using the information in our Contact Us section.
10. European Privacy Notice
This European Privacy Notice applies to any individuals located within the EEA, UK, or Switzerland from whom we may have collected personal data from any source, including through your use of our Sites, Products, and Services. We provide this European Privacy Notice to comply with applicable privacy laws, including the General Data Protection Act (“GDPR”), the UK GDPR, and related laws, regulations, and guidance from the European Union and/or its member states. Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy.
European law provides individuals located in Europe with rights to receive certain disclosures regarding the collection, use, and sharing of personal data, as well as rights to be informed, access, rectification, erasure, restrict processing, data portability and to object with respect to collected personal data. For the purposes of this European Privacy Notice, “personal data” means any information relating to an identified or identifiable natural person.
a. Basis for processing your personal data
Underlining relies on one or more legal bases to process your personal data under applicable law. We may process personal data (i) as necessary to perform our contractual obligations to you, including, but not limited to, those obligations in our terms of use; (ii) as necessary to pursue our legitimate interests as further detailed below; (iii) as necessary for our compliance with our legal obligations such as a request or order from courts, law enforcement or other government authorities; and/or (iv) with your consent, including to send you marketing email messages and other information that may be of interest to you, which you may withdraw at any time.
Legitimate business interests. We may collect, process, and maintain personal data to pursue the legitimate business interests outlined below. To determine these legitimate interests, we balance our legitimate interests against the legitimate interests and rights of you and others and only process personal data in accordance with those interests where they are not overridden by your data-protection interests or fundamental rights and freedoms.
While our legitimate interests are most extensively detailed in Section 2 of our Privacy Policy, they generally include:
b. Your privacy rights
In certain circumstances, individuals located within the EEA, UK, and Switzerland are entitled to the following data protection rights regarding their personal data:
Where the processing of your personal data is based on your previously provided consent, you have the right to withdraw your consent at any time. If you would like to exercise any of these rights, please submit a written request using the information in the Contact Us section below. We will respond to these requests in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
You may also have the right to lodge a complaint about our data collection and processing actions with the appropriate supervisory authority. You can view the contact information for your data protection authority here.
11. Links to Other Websites
Our Sites may contain links to other websites that are not operated by Underlining. We strongly suggest you review their privacy policies. If any linked website is not owned or controlled by us, we are not responsible for its content or privacy policies, or the practices of the operator of the website or services.
12. Changes to This Privacy Policy
We may change this Privacy Policy from time to time to reflect new services or changes in our data practices or relevant laws. The “effective date” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Sites. If we make any material changes to this Privacy Policy, we will take reasonable measures to notify you via email and/or a prominent notice on our Sites prior to the change becoming effective, and will update the effective date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes.
13. Contact Us
If you have any questions about this Privacy Policy or wish to exercise one of your privacy rights, please contact us using the following information:
Email: privacy@underlining.com
Phone: 1 (800) 936-1810
Address: Underlining, Inc.
1065 SW 8th Street PMB 668
Miami, FL 33130
Contact Form: https://freewillhair.com/pages/privacy-contact