PRIVACY POLICY

Last update: February 1, 2019

This privacy policy (“Privacy Policy”) describes how Chovain (“Chovain,” “we,” or “us”) collects, uses, and discloses your personal information; and the steps we take to protect it. If you have any questions regarding our privacy practices, please contact us. For the purposes of this Privacy Policy all references to Chovain shall be deemed to include its related companies (including all subsidiaries), its divisions and other companies that are part of its corporate group, its suppliers and licensors, as well as its employees, directors, administrators, shareholders, agents, subcontractors and other representatives.

This Privacy Policy applies to all of the services offered by Chovain, available through our website at www.chovain.com or through one of our mobile applications (the "Services"). Chovain and its affiliates may share information with each other and use it in a manner consistent with this Privacy Policy.

In addition to this Privacy Policy, the use of the Services is also subject to (i) our Terms of Service (available at www.chovain.com) and (ii) all other terms of use that may be communicated by Chovain from time to time.

If you do not agree to comply with these terms and conditions regarding our collection, use, communication, sharing, and management of personal information set out in this Privacy Policy, please do not use the Services and cease using them immediately.

PERSONAL INFORMATION THAT IS COLLECTED

Personal information is generally defined by applicable privacy or data protection laws as information about an identifiable individual. You may choose to give us personal information when you use our Services. For example, you could be asked to provide personal information when you sign up for our Services or when you begin a relationship with us through any means provided on the site, including your last name, first name, email address and cellular number. You may also provide us with information when you make a purchase or send us customer service-related requests. If you are a beauty professional offering your services on the Chovain application (a "Professional"), you may provide us with your bank account or other payment information in order to receive payments from us.

Other personal information is automatically collected when you use the Services, including your IP address.

We use the personal information described above for legitimate purposes which are detailed in the next section.

While your credit card and billing information (including your mailing address) may be requested through an accessible link on the Services, this information will only be communicated to the payment service provider (e.g. Stripe) in order to complete the transaction. Chovain does not obtain and does not keep your credit card number.

You may register for an account to offer your beauty services as a Professional on the Services by completing the required form on the Chovain website or in such other manner as may be approved by Chovain from time to time. In your application, you may be required to provide us with some information about your business as a Professional, such as your business name, address, email address, other contact information, the specific beauty services that you provide and pricing information. You acknowledge and agree that this information about your profile and business as a Professional is not personal information subject to this policy. This information will be displayed publicly on the Service and may be available to all visitors of the Chovain website or users of the Services.

COLLECTION AND USE OF PERSONAL INFORMATION

We collect personal information that you provide when you use functionalities of our Services, including when you participate in the following activities:

Making a purchase or completing a form on our Services;
Subscribing to our mailing list, newsletter and email communication in order to receive our latest news; and/or
Communicating with us to ask a question, submit a comment or file a complaint (customer service).

In general, the personal information that is collected is used to administer and deliver the Services. To help you better understand how your personal information will be used, you will find below a more detailed explanation on how your personal information will be used in relation to specific activities.

Making a purchase or completing a form on our Services. Our Services offer you the possibility to request information on the products and services offered through the Chovain application and the possibility to purchase services offered by Professionals. Therefore, we will use the personal information that is collected to process your request, to complete your transaction using the payment services offered by our preferred third-party payment services provider and when applicable, to deliver any information you may request or the products or services you have ordered. We will share your information, including name, phone, e-mail and address for in-home services, with Professionals in order to allow the Professionals to deliver the beauty-services you have requested.

Subscribing to our mailing list, newsletter and email communication. Sometimes, we may collect personal information to send you emails containing our latest news, products, services or promotions as well as those of third parties to whom we are linked. You can unsubscribe from our mailing list at all times by following the instructions provided at the end of every email. You can also unsubscribe from our mailing list by following the instructions set out in the section titled “Contact us” below. Your request will be processed within the statutory timeframes.

Communicating with us to ask a question, submit a comment or file a complaint (customer service). If you choose to send us an electronic feedback form or to send comments, questions or feedback via email, we collect some personal information as well as your comments, suggestions and feedback. This personal information is used to respond to your comments, questions or feedback. We can also keep this information to help you in the future. We can also use your comments, suggestions and feedback to monitor and/or enhance our products and service offerings and our Services.

Management database and customer relationship management (CRM). When you participate in one of the above-mentioned activities, we collect personal information provided to complete and update our customer relationship database. In this context, the personal information collected is used to manage the relationship with customers, to generate mailing lists, to follow up with potential clients and to create internal reports on relationships between Chovain and its clients to monitor and/or enhance our Services.

INFORMATION COLLECTED ON THE SERVICES

Cookies and other technologies. Some of our Services may use a technology called "cookies". A cookie is a tiny element of data that is sent to your device, which may then be stored on your device so we can identify you as an authorized user of our Services. The information recorded by cookies is encrypted and only Chovain is in a position to read the content of cookies in order to identify authorized users. You may set your web browser or other device to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Services, you may not be able to take advantage of all of the features of our Services.

A professional web analysis service. We can also use third parties, including Google, to:

Use the following features of Google Analytics: the creation of reports based on the saved impressions on Google Display Network (a service that lets you place ads on a variety of news sites, blogs and other niche sites) to attract more potential customers; integration with DoubleClick Campaign Manager (management tool including a set of features used for advertising as well as targeting and monitoring advertising campaigns on websites and mobile devices linked to them, as well as the creation of Google Analytics reports on the demographic data of internet users and their interests);

Collect, analyze and/or gather your personal information (such as internet users’ IP address, sex, age and interests), as well as create Google Analytics reports on the demographic data of internet users and their interests, in order to help us understand how visitors interact with our website and to improve our products and our websites.

The companies conducting remarketing can combine the use of first-party cookies (such as the Google Analytics cookies for example), and third-party cookies (like DoubleClick cookies), to (i) gather personal information; (ii) to inform, optimize and advertise based on your previous visits on our websites; and (iii) to determine the relationship between the registered visits to our websites and the advertising impressions, the other uses of advertising services and the interactions with these advertising impressions and these advertising services. To measure the effectiveness of our ads, these companies may also use tracer tags or web beacons to account for certain information regarding your visits to our websites and to the websites that have links to our site and that advertise it. If so desired, you can deactivate Google Analytics for the Display Ads. You can also customize the advertisements on the Google Display Network. Go to https://www.google.com/settings/ads to set your preferences.

DISCLOSURE OF PERSONAL INFORMATION

Principle. Unless specifically stated in this Privacy Policy, we will not disclose, trade, rent, sell or otherwise transfer your personal information, without your consent. Access to your personal information is restricted to Chovain, more specifically to their personnel, management and the marketing team who need access to this personal information as part of their functions for Chovain.

Exceptions. We may transfer your personal information to:

service providers, i.e. third parties (or otherwise make your personal information available to them) who provide services on our behalf in Canada, in the United States or abroad, including Google in order to use the various Google Analytics features described herein. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes.

to entities, organizations and authorities for legal purposes. In other words, we and our service providers can disclose your personal information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable law. We may also disclose personal information where necessary for the establishment, exercise or defense of legal claims and to prevent actual or suspect loss or harm to persons or property; and/or

to another entity in connection with a merger or sale including all or part of our company or as part of a corporate reorganization or stock sale or other change in corporate control. In that case, we may transfer your personal information to a third party as part of the transaction.

THIRD PARTY LINKS

Our Services may contain links to other sites that Chovain does not own or operate. Also, links to our Services may be featured on third party websites on which we advertise. Except as provided herein, we will not provide any of your personal information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

SECURITY OF PERSONAL INFORMATION

We have implemented, and we apply administrative, technical and physical measures aiming to protect the personal information in our custody and control against unauthorized access, use, modification and disclosure.

We have personal information retention processes designed to retain personal information of our customers for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.

ACCESS TO YOUR PERSONAL INFORMATION

You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request to access, update and correct inaccuracies in your personal information that we have in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of any individual seeking access or update to their personal information records.

CHANGES TO THE PRIVACY POLICY

This Privacy Policy may be updated periodically to reflect changes to the applicable laws or to our personal information practices. The revised Privacy Policy will be posted on our website. We will treat personal information in a manner consistent with the Privacy Policy in effect when we collect your information unless we have your consent to treat it differently.

WITHDRAWING YOUR CONSENT TO THE RETENTION, USE AND DISCLOSURE

You may withdraw your consent to our retention, use or disclosure of your personal information at any time by contacting us as set out below in the “Contact us section”. However, if you withdraw your consent, we may not be able to respond to your requests, process your requests or provide you with any help regarding the Services.

The Services are offered by 9378-0914 Québec inc. (doing business as CHOVAIN), a corporation incorporated under the laws of Québec, Canada.

If you have comments or questions about the way we use your personal information or if you would like to access, review, update, or correct the personal information in our custody, please contact us in the manner described below.

Attention of: Privacy Officer

Online: info@chovain.com