Paul Mitchell Advanced Education respects the privacy of its online visitors and customers of its products and services and complies with applicable laws for the protection of your privacy, including, without limitation, the European Union General Data Protection Regulation ("GDPR") and the Swiss and EU Privacy Shield Frameworks.
Wherever we talk about Personal Data below, we mean any information that can either itself identify you as an individual ("Personally Identifying Information") or that can be connected to you indirectly by linking it to Personally Identifying Information. Paul Mitchell Advanced Education also processes anonymous data, aggregated or not, to analyze and produce statistics related to the habits, usage patterns, and demographics of customers as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates. Paul Mitchell Advanced Education may share anonymous data, aggregated or not, with third parties.
2. Why Paul Mitchell Advanced Education Collects and Processes Data
Paul Mitchell Advanced Education collects and processes Personal Data for the following reasons:
a) where it is necessary for the performance of our agreement with you to provide a full-featured experience during your visit to our websites and social media
- b) where it is necessary for compliance with legal obligations that we are subject to (e.g. our obligations to keep certain information under tax laws);
c) where it is necessary for the purposes of the legitimate and legal interests of Paul Mitchell Advanced Education or a third party (e.g. the interests of our other customers), except where such interests are overridden by your prevailing legitimate interests and rights; or
d) where you have given consent to it.
These reasons for collecting and processing Personal Data determine and limit what Personal Data we collect and how we use it (section 3. below), how long we store it (section 4. below), who has access to it (section 5. below) and what rights and other control mechanisms are available to you as a user (section 6. below).
What Data We Collect and Process
3.1 Basic Account Data
When you request information from a Paul Mitchell School, Paul Mitchell Advanced Education will collect your email address and country of residence. In some instances you are also required to choose a user name and a password. The provision of this information is necessary to register a Paul Mitchell Advanced Education User Account. During setup of your account, the account is automatically assigned a number (the "Paul Mitchell Advanced Education ID") that is later used to reference your user account without directly exposing Personally Identifying Information about you.
3.2 Transaction and Payment Data
In order to make a transaction on Paul Mitchell Advanced Education (e.g. to pay any school fees online), you may need to provide payment data to Paul Mitchell Advanced Education to enable the transaction. If you pay by credit card, you need to provide typical credit card information (name, address, credit card number, expiration date and security code) to Paul Mitchell Advanced Education, which Paul Mitchell Advanced Education will process and transmit to the payment service provider of your choice to enable the transaction and perform anti-fraud checks. Likewise, Paul Mitchell Advanced Education will receive data from your payment service provider for the same reasons.
3.3 Other Data You Explicitly Submit
We will collect and process Personal Data whenever you explicitly provide it to us or send it as part of communication with others on Paul Mitchell Advanced Education, e.g. in Paul Mitchell Advanced Education Community Forums, chats, or when you provide feedback or other user generated content. This data includes:
- Information that you post, comment or follow in any of our Content and Services;
- Information sent through chat;
- Information you provide when you request information or support from us or purchase Content and Services from us, including information necessary to process your orders with the relevant payment merchant or, in case of physical goods, shipping providers;
- Information you provide to us when participating in competitions, and contests or responding to surveys, e.g. your contact details.
3.4 Your Use of the Paul Mitchell Advanced Education Websites
We collect a variety of information through your general interaction with the websites, Content and Services offered by Paul Mitchell Advanced Education.
Personal Data we collect may include, but is not limited to, browser and device information, data collected through automated electronic interactions and application usage data.
Likewise, we will track your process across your websites and applications to verify that you are not a bot and to optimize our services.
3.5 Tracking Data and Cookies
When you visit any of our services, our servers log your global IP address, which is a number that is automatically assigned to the network your computer is part of.
3.6 Google Analytics
This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on visitors' computers, to help the website operators analyze how visitors use the site. The information generated by the cookie about the visitors' use of the website will generally be transmitted to and stored by Google on servers in the United States.
On this website, IP anonymization has been activated. The IP addresses users visiting Paul Mitchell Advanced Education will be shortened. Only in exceptional cases will a complete IP address be transferred to a Google server in the United States and shortened there. On behalf of the website operator, Google will use this information for the purpose of evaluating the website for its users, in order to compile reports on website activity, and to provide other services relating to website activity and internet usage for website operators.
Furthermore, users can prevent the collection of data about their use of the website (including their IP address) generated by the cookie, and the processing of data by Google, by downloading and installing the browser plug-in through the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
4. How Long We Store Data
We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or — where the applicable law provides for longer storage and retention period — for the storage and retention period required by law. After that your Personal Data will be deleted, blocked or anonymized, as provided by applicable law.
- Please note that Paul Mitchell Advanced Education is required to retain certain transactional data under statutory commercial and tax law for a period of up to ten (10) years.
- If you withdraw your consent on which a processing of your Personal Data or of the Personal Data of your child is based, we will delete your Personal Data respectively the Personal Data of your child without undue delay to the extent that the collection and processing of the Personal Data was based on the withdrawn consent.
- If you exercise a right to object to the processing of your Personal Data, we will review your objection and delete your Personal Data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless applicable law requires us to retain the data.
Who Has Access to Data
5.1 Paul Mitchell Advanced Education and its subsidiaries may share your Personal Data with each other and use it to the degree necessary to achieve the purposes listed in section 2. above. In the event of a reorganization, sale or merger we may transfer Personal Data to the relevant third party subject to applicable laws.
5.3 In accordance with internet standards, we may also share certain information (including your IP address and the identification of Paul Mitchell Advanced Education content you wish to access) with our third party network providers that provide content delivery network services and game server services in connection with Paul Mitchell Advanced Education. Our content delivery network providers enable the delivery of digital content you have requested, e.g. when using Paul Mitchell Advanced Education, by using a system of distributed servers that deliver the content to you, based on your geographic location.
5.4 Paul Mitchell Advanced Education may release Personal Data to comply with court orders or laws and regulations that require us to disclose such information.
6. Your Rights and Control Mechanisms
As a resident of the European Economic Area you have the following rights in relation to your Personal Data:
6.1 Right of Access.
You have the right to access your Personal Data that we hold about you, i.e. the right to require free of charge (i) information whether your Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained. You can use the right to access to your Personal Data through the Privacy Dashboard. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request.
6.2 Right to Rectification.
If we process your Personal Data, we shall endeavor to ensure by implementing suitable measures that your Personal Data is accurate and up-to-date for the purposes for which it was collected. If your Personal Data is inaccurate or incomplete, you can change the information you provided via the Privacy Dashboard.
6.3. Right to Erasure.
You have the right to obtain deletion by us of Personal Data concerning you by deleting your Paul Mitchell Advanced Education User Account via the Paul Mitchell Advanced Education support email address email@example.com.
6.4 Right to Object.
You also have the right to lodge a complaint at a supervisory authority.
7. Contact Info
You can contact Paul Mitchell Advanced Education's data protection officer at the address below.
While we review any request sent by mail, please be aware that to combat fraud, harassment and identity theft, the only way to rectify or delete your data is through our support email address firstname.lastname@example.org.
Paul Mitchell Advanced Education
Att. IT Department
9756 S Sandy Parkway
Sandy, UT 84070
8. Additional Information for Users from the European Economic Area
In compliance with the Privacy Shield Principles, Paul Mitchell Advanced Education commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Paul Mitchell Advanced Education here. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. As explained in the Privacy Shield documentation (https://www.privacyshield.gov/article?id=ANNEX-I-introduction) certain residual claims not resolved by other means may be subject to binding arbitration. In such event, an arbitration option will be made available to you.
The Privacy Shield Principles describe Paul Mitchell Advanced Education's accountability for Personal Data that it subsequently transfers to a third party agent. Under the Principles, Paul Mitchell Advanced Education shall remain liable if third party agents process the personal information in a manner inconsistent with the Principles, unless Paul Mitchell Advanced Education proves it is not responsible for the event giving rise to the damage.
The Federal Trade Commission has jurisdiction over Paul Mitchell Advanced Education's compliance with the Privacy Shield.
Revision Date: May 25, 2018