Privacy Policy

‍Effective Date: June 5, 2026

1. Introduction

This Privacy Policy describes how Creative Laboratories, Inc. (“Creative Labs,”  “we,” “us,” or “our”), collects, uses, discloses, and protects the personal information we maintain from and about your interactions with us, including when you visit our websites, mobile sites, or online service that links to this Privacy Policy (collectively, the “Sites”).

Our products may be available for purchase through third-party retailers and online marketplaces, including Amazon, Ulta.com, and Target.com. This Privacy Policy does not apply to those retailers or our handling of your personal information when fulfilling orders from those retailers. If you have questions about a purchase made through a retailer, please consult that retailer’s privacy policy and customer service channels. 

2. Personal Information We Collect

“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. 

Depending on how you interact with us, we may collect the following categories of personal information about you:

• Identifiers: such as your name, email address, phone number, address, birthdate, and similar identifiers.
• Commercial information: including products purchased, order history, shipping address, billing address, and payment information. Full payment card numbers are handled by our payment processor; we receive a tokenized reference and basic transaction metadata.
• Customer record information: such as information you provide when contacting us by email, contact form, phone, social media, chat or otherwise, including the content of your communications. Customer record information also includes, for example, quiz and preference responses (e.g., hair type, hair length, styling preferences), marketing preferences (e.g., opt-in and opt-out records), product reviews, ratings, and comments, and loyalty and rewards program information. 
• Internet activity information: including pages and products viewed, items added to cart, search terms, click paths, time spent on pages, referring and exit URLs, and dates and times of visits. We collect this information via cookies, pixels, tags, and similar technologies. For more information on our cookie policy, please see Section 6 (Cookies and Tracking Technologies).
• Geolocation information: such as general location derived from IP address or similar technologies.
• Professional information: including information related to your business or salon name, role, license information, and professional contact details, as applicable, when you sign up for our Stylist Signup or trade program.
• Sensitive Personal Information: such as your account log-in and password, or date of birth as provided to us in connection with a promotional program. We do not use or disclose your sensitive Personal Information for any purpose other than as permitted by applicable law.
• Inferences: We may also use inferences drawn from any of the information above to create a profile about your preferences, characteristics, and behaviors.

In addition to Personal Information, we may collect information that is not identifiable. For example, we may collect our app users’ browser types, device types, and operating system information and not connect it to other pieces of their data. If, however, we do link this information to other information that can be used to identify you, we will treat such information as Personal Information.

3. Sources of Personal Information

We collect personal information from or about you from the following sources:

• Directly from you: We collect your Personal Information when you make a purchase from us, sign up for email, participate in our hair-color preference quiz, contact us, or otherwise engage with our brands.
• Automatically through data collection technologies: When you visit our Sites, we and our service providers and advertising partners automatically collect Personal Information about your device and your interactions with the Sites.
• From third parties: We may obtain Personal Information about you from third parties, such as retailers, service providers, credit reporting agencies, partners with whom we offer co-branded services or engage in joint marketing activities, and publicly available sources and social media platforms.

We may combine information that we receive from the various sources described in this Privacy Policy, including third party sources, and use and disclose the combined information for the purposes identified below.

4. How We Use Personal Information

How use your Personal Information depends on the reason we collected it and how we may be required or permitted to use it for our general business purposes. Generally, we use your Personal Information for the following purposes:

• Providing our services to you. We process your Personal Information to deliver the services you or our business customers (such as third-party retailers) request; manage registrations and accounts; handle returns, refunds, and exchanges; and send administrative and transactional communications, pursuant to our contracts and to operate and administer our websites, products, and other services. 
• Handling contact and support requests. If you request support or otherwise contact us, we process your Personal Information pursuant our contract with you and to the extent it is necessary to fulfill your requests and communicate with you.
• Sending marketing communications. We will process your Personal Information to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, or push notifications) about us. This may include delivering targeted advertising based on your preferences or interests across services and devices and measuring the effectiveness of ads.
• Operating our loyalty and rewards program. We will process your Personal Information to track points earned and redeemed, process reward redemptions, communicate program updates, administer referral and tier-status benefits, and otherwise administer our loyalty and rewards program. 
• Developing and improving our services. We process your Personal Information to analyze trends, track your usage of and interactions with our services, assess and improve the overall user and customer experience. This is sometimes done pursuant to your consent and to the extent necessary for us to develop and improve those services and provide our users with more relevant content and service offerings.
• Complying with law and other legal processes. We process your Personal Information when cooperating with public and government authorities, courts, or regulators in accordance with our legal obligations under applicable laws. We may also process Personal Information to protect our rights and as necessary for us to protect against misuse or abuse of our services, protect personal property or safety, pursue remedies available to us, limit our damages, comply with judicial proceedings, court orders, or legal processes, and respond to lawful requests.
• With your consent or as otherwise disclosed at the time of collection.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law. We will maintain and use such information in de-identified form and will not attempt to re-identify it except as permitted by law. 

We may also collect, use, or sell Personal Information for the purpose of training large language models, pursuant to your consent.

5. How We Share Personal Information

We share personal information with the following categories of recipients:

• Service Providers: We share personal information with vendors who process information on our behalf under contracts that restrict their use to the purposes we specify. The categories of service providers include but are not limited to technology service providers, analytics service providers and marketing service providers.
• Advertising Partners: We may share your Personal Information with companies that help us display digital ads and track conversions. 
• Affiliates: We may share personal information with our parent, subsidiaries, and other corporate affiliates for the purposes described in this Privacy Policy, including consolidated marketing and customer service.
• Business Transfers: If Creative Labs is involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of all or a portion of its assets, or transition of service to another provider, your Personal Information may be transferred or disclosed as part of that transaction.
• Legal and Safety Disclosures: We may disclose your Personal Information if we determine that the disclosure is necessary: (i) to comply with any law applicable to us, a request from law enforcement, a regulatory agency, or other legal process; (ii) to protect the rights, privacy, property, interests or safety of Creative Labs, our business partners, personnel, or the general public; (iii) to pursue available remedies or limit damages; (iv) to enforce our policies and procedures; or (v) to respond to an emergency.
• With Your Consent or at Your Direction

We may share personal information with other parties when you direct us to or otherwise consent.

6. Cookies and Tracking Technologies

We and our service providers and advertising partners use cookies, pixels, tags, software development kits (SDKs), local storage, and similar technologies (collectively, “cookies”) on our Sites. Cookies help us configure our services so that they display property on your device, identify traffic pattens on our website so that we may improve your experience, and remember your preferences the next time you log in. We also use cookies for advertising purposes. Some of the digital ads we serve may be tailored to your interests and behaviors, including across other websites and services. To learn more about cookies and web beacons, visit www.allaboutcookies.org.

While the cookies we may use change from time to time, they generally fall into one of the following categories:

• Strictly necessary cookies: required to operate the Sites, including authenticating users, maintaining your shopping cart, and processing checkout. These cannot be disabled through our preference center.
• Functional cookies: These are technologies that help enhance functionality, improve your user experience, and tailor your use of our Sites. For example, functionality cookies can be used to remember your preferences (such as language or region) and enable enhanced features.
• Analytics cookies: These technologies help us understand how visitors use the Sites so we can measure and improve performance (such as Google Analytics or Shopify Analytics). For example, we gather analytics to help us understand which pages within our Sites are most popular and how users move around them.
• Advertising and targeting cookies: These are technologies used by us and our advertising partners to deliver advertising relevant to your interests on our Sites and on third-party platforms, and to measure ad performance.

Setting Your Preferences

Some web browsers (including some mobile web browsers) and mobile devices provide settings that allow you to control or reject cookies or alert you when they are placed on your device. Depending on where you live, you may also see a banner or preference center that gives you options and controls over the cookies that we use when you visit our online services.  If you reject certain cookies, some features of our online services may not function properly. You can also manage advertising cookies and “sharing” for cross-context behavioral advertising through the controls described in Sections 7 and 8.

Google Analytics Disclosure

We use Google Analytics, a web-based analytics tool that tracks and reports on ways the website is used to help us to improve it. Google Analytics does this by placing cookies on your device. For more information about Google’s ability to use and share information collected by Google Analytics about your visits to the Sites, please see the Google Analytics Terms of Service and the Google Privacy Policy.

Do Not Track Signals

Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes; however, we do not currently recognize or respond to browser-initiated DNT signals.

Global Privacy Control

Individuals can automatically signal their privacy preferences to websites and other online services through their browser or through a browser extension called the Global Privacy Control (“GPC”). Depending on where you live, we may take steps to honor your preferences set by the GPC or any similar reputable universal opt-out mechanism.

7. Your Privacy Choices

Marketing Email

You can unsubscribe from marketing email at any time by clicking the “unsubscribe” link at the bottom of any marketing message or by emailing us at [PRIVACY_EMAIL]. Even after you unsubscribe from marketing, we may still send you administrative messages (for example, order confirmations and shipping updates).

Account Information

You can review and update your account information by logging in to your account or by contacting us at [PRIVACY_EMAIL]. You may also request that we delete your account, subject to applicable law (see Section 8).

Do Not Sell or Share My Personal Information

California residents and residents of certain other states have the right to opt out of “sale” and “sharing” of personal information for cross-context behavioral advertising. To exercise this right:

• Use the “Do Not Sell or Share My Personal Information” link in the footer of our Sites.
• Email us at [PRIVACY_EMAIL] with the subject line “Do Not Sell or Share.”

8. US State Privacy Rights and Disclosures

This Section 8 describes additional rights and disclosures that apply to residents of certain US states. If you are a resident of a state listed below, the rights described here are in addition to the choices in Section 7.

8.A California Disclosures

Processing Disclosures

If you are a resident of California, this Privacy Policy describes our Personal Information collection, use, and disclosure practices over the past 12 months. In addition, for Personal Information that we control:

• We have sold or shared, as defined by California law, the following categories of personal data with our Advertising Partners: online identifiers, device information, internet or other electronic activity information, and purchase information.
• We do not knowingly sell Personal Information of minors under 16.
• We do not otherwise sell Personal Information in exchange for monetary consideration.

In addition to the rights and choices outlined above, you may also request to exercise the following privacy rights:

• Right to know: The right to request to know what Personal Information we collected about you (categories and specific data elements), from where we collected it, why we have collected, sold, or shared it, and to whom we have disclosed it. 
• Right to delete: The right to request that we delete Personal Information we collected from you. 
• Right to correct: The right to correct inaccurate Personal Information we maintain about you.
• Right to opt out: The right to opt out of certain automated processing and profiling activities, as well as the sale and sharing of your Personal Information for targeted advertising purposes. We do not currently engage in practices involving automated decision-making, profiling, or selling Personal Information other than as disclosed in this Privacy Policy.

You can exercise your privacy rights as described in the “Exercising Your Rights” section, below. 

Financial Incentive Notice (Loyalty/Rewards Program)

We may offer financial incentives to consumers in exchange for sharing certain personal information with us. Participation and the rewards offered as incentives are set out within each program. Our good faith estimate of the value of your information is the value of the benefit we offer to you. We calculate that value by using the expense to us of operating the program related to the benefit obtained by running the program. You can opt in by signing up for the incentive when it is offered to you. Participation is always optional, and you can withdraw or opt out of participating at any time by emailing [PRIVACY_EMAIL] with the subject line “Cancel Loyalty Enrollment,” or as otherwise explained in the applicable program terms.

Shine the Light

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for those third parties’ direct marketing purposes and the names and addresses of all third parties to whom we disclosed Personal Information in the immediately preceding calendar year. To request this list or to opt out of these disclosures, email [PRIVACY_EMAIL] with the subject line “Shine the Light Request.”

8.B Other US State Disclosures

Residents of Texas, Nebraska, and certain other states may also request to exercise the following privacy rights (subject to any applicable exemptions and limitations):

• Right to access: You have the right to right to confirm whether we are processing your Personal Information and to access it.
• Right to correct: You have the right to correct inaccurate Personal Information that we maintain about you.
• Right to delete: You have the right to request that we delete your Personal Information under specific circumstances.
• Right to data portability: You have the right to request a copy of your Personal Information in an accessible format.
• Right to opt out: You have the right to object or opt out of certain types of processing, including: (1) processing for the purpose of targeted advertising, (2) processing for the purpose of the sale of Personal Information, and (3) processing for the purpose of certain types of profiling and automated decision-making. The right to opt out of certain automated processing and profiling activities, as well as the sale and sharing of your Personal Information for targeted advertising purposes. We do not currently engage in practices involving automated processing, profiling, or selling Personal Information other than disclosed in this Privacy Policy. 
• Right to appeal: If we do not grant your consumer request, you may have the right to appeal that denial.

If you are a resident of Connecticut, Oregon, or Minnesota, you also have the right to request a list of third parties to whom we disclose Personal Information.

8.C Exercising Your Rights

To exercise any of the rights listed in the above sections, you can contact us by email at [PRIVACY_EMAIL] or [TOLL-FREE NUMBER] with your state of residence in the subject line (for example, “California Privacy Request” or “Texas Privacy Request”). We will respond within the timeframes required by applicable law. 

We may take steps to verify your identity and the identity of an authorized agent (if such authorized agent is permitted by law) prior to reviewing your request. This may include requesting that you provide information that we can use to verify against our records and/or provide proof of appointing an agent.

If you choose to exercise any of these rights, we will not retaliate or discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our services. If we deny your request, you may appeal by replying to our response with the subject line “Appeal,” and we will respond within the appeal timeframe required by your state’s law. If you are not satisfied with the outcome of your appeal, you may contact your state attorney general.

Please note that if we are not required to comply with the privacy laws in your state, we may not honor your requests to exercise your rights.

9. Children’s Privacy

Our online services are not directed to or intended for use by minors. Consistent with applicable laws, if we learn that we have received Personal Information directly from a child without his or her parent or legal guardian’s verified consent, we will use that Personal Information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our services. Subsequently, we will delete such Personal Information in accordance with applicable legal requirements. If you believe that we might have any Personal Information from or about a child under the age of 18, please contact us.

10. Data Retention

We retain Personal Information for as long as needed to fulfill the purposes described in this Privacy Policy or our contracts with our business customers, as applicable, unless a longer retention period is required or permitted by law. When determining how long to retain information, we consider the amount, nature, and sensitivity of the information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process it; and applicable legal, regulatory, and accounting requirements.

11. Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, and destruction. These safeguards include encryption of personal information in transit, access controls, vendor diligence, and security monitoring. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted through the online services. You are responsible for keeping your account credentials confidential.

12. Third-Party Sites, Links, and Services

Our Sites may contain links to or embed content from third-party websites and services that we do not operate or control, including but not limited to social media platforms, retailers, payment providers, and influencer content. We are not responsible for the privacy practices of those third parties. If you provide your Personal Information to that third party through its websites or services, you will be subject to that third party’s privacy practices and policies. This Privacy Policy does not apply to any Personal Information that you provide to a third-party website or service. We encourage you to review the privacy policies of any third-party site or service before providing Personal Information to it. A link or reference to a third-party website or service does not mean that we endorse that third party or the quality or accuracy of the information presented on its website or service.

13. Geographic Scope; Users Outside the United States

If you are visiting the website from outside the United States, please be aware that Creative Labs is based in the United States and the information we collect will be transferred to, processed and stored on our servers in the United States in accordance with this Privacy Policy and applicable laws. The data protection laws and regulations applicable to your Personal Information transferred to the United States may be different from the laws in your country of residence.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We state the Effective Date of this Privacy Policy at the top of this page. When we make material changes or disclose your Personal Information, we will endeavor to notify you in advance by email and/or by placing a prominent notice on our services.  The amended Privacy Policy supersedes all previous versions. We encourage you to review this Privacy Policy periodically.

15. Contact Us

If you have questions about this Privacy Policy or our privacy practices, you can reach us using the following information. Please identify to which Creative Labs brand your message is related in the content of your message. 

Creative Laboratories, Inc.

Attn: Privacy

[MAILING ADDRESS]

[CITY], [STATE] [ZIP]

Email: [PRIVACY_EMAIL] 

Toll-free: [INSERT NUMBER]