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Privacy Statement

Welcome to St Michael Holdings Ltd.!

St Michael Holdings Ltd., and its affiliates (collectively “Brothers Hair Academy”, “we” and “us”) respect your privacy. We offer services that enable platforms and merchants to run businesses, and to safely conduct online payment transactions. This Global Privacy Policy describes the types of Personal Data we collect through our payments products and services (“Services”) and via our online presence, which include our main website as , as well as services and websites that we enable Internet users to access, such as Brothers Hair Academy’s Cart and the Brothers Hair Academy’s Shop (collectively, our “Sites”). This policy also describes how we use Personal Data, with whom we share it, your rights, and choices, and how you can contact us about our privacy practices. This policy does not apply to third-party websites, products, or services, even if they link to our Services or Sites, and you should consider the privacy practices of those third parties carefully. This Privacy Policy is provided in a layered format. Click through to jump to a specific section.

Overview

Personal Data We Collect

How We Use Personal Data

How We Disclose Personal Data

Your Rights and Choices

Security and Retention

International Data Transfers

Use by Minors

Updates To this Privacy Policy

Links To Other Websites

Jurisdiction-specific Provisions

Contact Us

1. Overview

Brothers hair Academy obtains Personal Data about you from various sources to provide our Services and to manage our Sites. “You” may be a visitor to one of our websites, a user of one or more of our Services (“User” or “Brothers Hair Academy’s User”), or a customer of a User (“Customer”). If you are a Customer, Brothers Hair Academy’s will generally not collect your Personal Data directly from you. Your agreement with the relevant Brothers Hair Academy’s User should explain how the Brothers Hair Academy’s User shares your Personal Data with Brothers Hair Academy’s , and if you have questions about this sharing, then you should direct those questions to the Brothers Hair Academy’s User. Learn more

2. Personal Data We Collect

a. Personal Data that we collect about you. Personal Data is any information that relates to an identified or identifiable individual. The Personal Data that you provide directly to us through our Sites and Services will be apparent from the context in which you provide the data. In particular: When you register for a Brothers Hair Academy’s account, we collect your full name, email address, and account log-in credentials. When you fill-in our online form to contact our sales team, we collect your full name, work email, country, and anything else you tell us about your project, needs and timeline. When you use the “Remember Me” feature of Brothers Hair Academy’s Checkout, we collect your email address, payment card number, CVC code and expiration date. When you respond to Brothers Academy’s emails or surveys, we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call Brothers Hair Academy’s. If you contact us by phone as a Brothers Hair Academy’s User, we may collect additional information in order to verify your identity. If you are a Brothers Hair Academy’s User, you will provide your contact details, such as name, postal address, telephone number, and email address. As part of your business relationship with us, we may also receive financial and personal information about you, such as your date of birth and government identifiers associated with you and your organisation (such as your social security number, tax number, or Employer Identification Number). If you are a Customer of a Brothers Hair Academy’s User, when you make payments or conduct transactions through a Brothers Hair Academy’s User’s website or application or device we provide, we will receive your transaction information. Depending on how the Brothers Hair Academy’s User implements our Services, we may receive this information directly from you, or from the Brothers Hair Academy’s User or third parties. The information that we collect will include payment method information (such as credit or debit card number, or bank account information), purchase amount, date of purchase, and payment method. Different payment methods may require the collection of different categories of information. The Brothers Hair Academy’s User will determine the payment methods that it enables you to use, and the payment method information that we collect will depend upon the payment method that you choose to use from the list of available payment methods that are offered to you by the Brothers Hair Academy’s User. When you make a transaction, we may also receive your name, email, billing or shipping address and in some cases your transaction history to authenticate you. When we conduct fraud monitoring, prevention, detection, and financial compliance activities or provide such services to our Users, we will receive Personal Data from you (and your device) and about you through our Service and from our business partners, financial service providers, identity verification services, and publicly available sources (e.g., name, address, phone number, country), as necessary to confirm your identity and prevent fraud. Our fraud monitoring, detection and prevention services may collect Personal Data about you and use technology to help us assess the risk associated with an attempted transaction by you with a Brothers Hair Academy’s User. You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details at trade shows or other events.

b. Information that we collect automatically on our Sites. Our Sites use cookies and other technologies to function effectively. These technologies record information about your use of our Sites, including: Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting; Usage data, such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites. 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. We use Google Analytics on our Sites to help us analyse Your use of our Sites and diagnose technical issues. To learn more about the cookies that may be served through our Sites and how You can control our use of cookies and third-party analytics, please see our Cookie Policy.

3. How We Use Personal Data

a. Our products and services. We rely upon several legal grounds to ensure that our use of your Personal Data is compliant with applicable law. We use Personal Data to facilitate the business relationships we have with our Users, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests. We also use Personal Data to complete payment transactions and to provide payment-related services to our Users. Learn more

b. Marketing and events-related communications. We may send you email marketing communications about Brothers Hair Academy’s products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law. For example, when we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns.

c. Advertising. When you visit our Sites, we (and our service providers) may use Personal Data collected from you and your device to target advertisements for Brothers Hair Academy’s Services to you on our Sites and other sites you visit (“interest-based advertising”), where allowed by applicable law. For example, when you visit our Site, we will use cookies to identify your device and direct ads for our Services to you. You have choices and control over our cookies (or similar technologies) we use to advertise to you. Please see our Cookie Policy for more information. At present, there is no industry standard for recognising Do Not Track browser signals, so we do not respond to them. We do not use, share, rent or sell the Personal Data of our Users’ Customers for interest-based advertising. We do not sell or rent the Personal Data of our Users, their Customers or our Site visitors.

4. How We Disclose Personal Data.

Brothers Hair Academy’s does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below. a. Brothers Hair Academy’s. We share Personal Data with other Brothers Hair Academy’s entities in order to provide our Services and for internal administration purposes.

b. Service providers. We share Personal Data with a limited number of our service providers. We have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union and the United States of America.

c. Business partners. We share Personal Data with third party business partners when this is necessary to provide our Services to our Users. Examples of third parties to whom we may disclose Personal Data for this purpose are banks and payment method providers (such as credit card networks) when we provide payment processing services, and the professional services firms that we partner with to deliver Stripe Atlas.

d. Our Users and third parties authorized by our Users. We share Personal Data with Users as necessary to maintain a User account and provide the Services. We share data with parties directly authorized by a User to receive Personal Data, such as when a User authorizes a third party application provider to access the User’s Stripe account using Stripe Connect. The use of Personal Data by an authorized third party is subject to the third party’s privacy policy.

e. Corporate transactions. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us, or part of our business will have the right to continue to use your Personal Data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

f. Compliance and harm prevention. We share Personal Data as we believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of Brothers Hair Academy’s , you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

5. Your Rights and Choices.

You have choices regarding our use and disclosure of your Personal Data:

a. Opting out of receiving electronic communications from us. If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.

b. How you can see or change your account Personal Data. If You would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by signing in to your Stripe account or by contacting us.

c. Your data protection rights. Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you: The right to request confirmation of whether Stripe processes Personal Data relating to you, and if so, to request a copy of that Personal Data; The right to request that Stripe rectifies or updates your Personal Data that is inaccurate, incomplete, or outdated. The right to request that Stripe erase your Personal Data in certain circumstances provided by law. The right to request that Brothers Hair Academy’s restrict the use of your Personal Data in certain circumstances, such as while Stripe considers another request that you have submitted (including a request that Stripe make an update to your Personal Data); and The right to request that we export to another company, where technically feasible, your Personal Data that we hold to provide Services to you. Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your Personal Data on grounds relating to your situation.

d. Process for exercising data protection rights. In order to exercise your data protection rights, you may contact Stripe as described in the Contact Us section below. We take each request seriously. We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may consult with the data protection authority in your country. For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request. If you are a Customer of a Brothers Hair Academy’s User, please direct your requests directly to the User. For example, if you are making, or have made, a purchase from a merchant using Stripe as a payment processor, and you have a request that is related to the payment information that you provided as part of the purchase transaction, then you should address your request directly to the merchant.

6. Security and Retention.

We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organizational, technical, and administrative measures designed to protect Personal Data within our organization against unauthorized access, destruction, loss, alteration or misuse. Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately. We retain your Personal Data if we are providing the Services to you. We retain Personal Data after we cease providing Services directly or indirectly to you, even if you close your Stripe account or complete a transaction with a Stripe User, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

7. International Data Transfers.

We are a global business. Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data. If you are located in the European Economic Area (“EEA”), the UK or Switzerland, we comply with applicable laws to provide an adequate level of data protection for the transfer of your Personal Data to the US. Luke Anthony’s is certified under the EU-U.S. and the Swiss-U.S. Privacy Shield Framework and adheres to the Privacy Shield Principles in connection with personal data transfers from the EEA, the UK and Switzerland. For more, see Stripe’s Privacy Shield Policy. In addition, we have implemented intra-group data transfer agreements which you may view upon request. Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use one or more of the following mechanisms: EU Standard Contractual Clauses with a data recipient outside the EEA or the UK, verification that the recipient has implemented Binding Corporate Rules, or verification that the recipient adheres to the EU-US and Swiss-US Privacy Shield Framework.

8. Use by Minors.

The Services are not directed to individuals under the age of thirteen (13), and we request that they not provide Personal Data through the Services.

9. Updates To this Privacy Policy and Notifications.

We may change this Privacy Policy from time to time to reflect new services, changes in our Personal Data practices or relevant laws. The “Last updated” 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 Services. We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if you are a User, by contacting you through your Stripe Dashboard, email address and/or the physical address listed in your Stripe account.

10. Links To Other Websites.

The Services may provide the ability to connect to other websites. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website.

11. Jurisdiction-specific Provisions.

Australian residents. The Stripe entity that provides Services in Australia is Stripe Payments Australia Pty. Ltd. If you are an Australian resident, and you are dissatisfied with our handling of any complaint you raise under this Privacy Policy, you may wish to contact the Office of the Australian Information Commissioner. Residents of the European Economic Area (EEA), the UK and Switzerland. The entity responsible for the collection and processing of Personal Data for residents of the EEA, the UK and Switzerland is Stripe Payments Europe, Ltd., a company incorporated in Ireland and with offices at 1 Grand Canal Street Lower, Grand Canal Dock, Dublin. To exercise your rights, the Data Protection Officer may be contacted via dpo@stripe.com. If you are a resident of the EEA and believe we process your information in scope of the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the Office of the Data Protection Commissioner. If you are a resident of the UK and the UK is no longer a Member State of the EU, you may direct your questions or concerns to the UK Information Commissioner’s Office. Mexican residents. Mexican residents may exercise data protection rights to access, correction, deletion, opposition or revocation under applicable law. You may be provided with further information about the steps to exercise your privacy rights, including identity verification, timing, the way to get in touch with the organization responding to your request for further communications about your request, and how your request may be honoured. If you are a Mexican resident and a Customer of a Stripe User, please direct your requests directly to the Stripe User with whom you shared your personal information. United States – California residents. This section provides additional details about the personal information we collect about California consumers as well as the rights of California consumers under the California Consumer Privacy Act (CCPA).

a. How We Collect, Use, and Disclose your Personal Information. The Personal Data We Collect section describes the personal information we may have collected over the last 12 months, including the categories of sources of that information. We collect this information for the purposes described in the How We Use Personal Data section. We share this information as described in the How We Disclose Personal Data section. Stripe uses cookies, including advertising cookies, as described in our Cookie Policy.

b. Your CCPA Rights and Choices. As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information: Exercising the right to know. You may request, up to twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months: the categories and specific pieces of personal information we have collected about you. the categories of sources from which we collected the personal information. the business or commercial purpose for which we collected the personal information. the categories of third parties with whom we shared the personal information; and the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose. Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law. Exercising the right to opt-out from a sale. You may request to opt out of any “sale” of your personal information that may take place. As described in Advertising, we do not use, share, rent or sell the Personal Data of our Users’ Customers for interest-based advertising. We do not sell or rent the Personal Data of our Users, their Customers, or our Site visitors. Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights. To submit a request to exercise any of the rights described above, you may contact Stripe at privacy@stripe.com. We may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. Authentication based on a government-issued and valid identification document may be required. If you are a Customer of a Stripe User, please direct your requests directly to the Stripe User with whom you shared your personal information.

12. Contact Us

If You have any questions or complaints about this Privacy Policy, please electronically contact us by visiting https://brothershairacademy.com/contact-us/ or send physical mail to:

St Michael Holdings Ltd.

Kemp House, City Road

London, EC1V 2NX, United Kingdom