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POLICY CONCERNING
THE PROTECTION OF PERSONAL INFORMATION

 

Introduction
In the course of providing our services, we may collect Personal Information from you.  We have prepared this policy to inform you about our ongoing commitment to ensuring that the Personal Information obtained during the course of our activities remains accurate and confidential.  For purposes of this policy, the terms “we,” “us,” and “our” refer to Regis Holdings (Canada) Ltd., First Choice Haircutters Ltd., Magicuts Ltd., and their related companies operating or franchising hair salons in Canada. 

What is Personal Information?
We consider "Personal Information" to mean any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information, other than business contact information (e.g. name, title, business address).  This Policy does not cover aggregated data from which the identity of an individual cannot be determined.  We retain the right to use aggregated data in any way that we deem appropriate. 

Why We May Collect Personal Information
We may use the Personal Information provided verbally or in writing (including via electronic media) by prospective and existing customers and clients, franchisees and other third parties in order to:
(a) Manage our ongoing relationship with customers, clients, franchisees, and others;
(b) Meet legal and regulatory requirements;
(c) Review franchise applications and determine suitability for franchise opportunities;
(d) Provide training, information, and advice to franchisees;
(e) Provide training and in-salon workshops to employees of our franchisees;
(f) Assist franchisees in setting-up and managing a salon; and
(g) Such other purposes consistent with these purposes. 

Where we are involved in operating a hair salon, we may use the Personal Information provided by customers and clients in order to: 

(a) Keep a log of client appointments;
(b) Provide appropriate hair care and esthetics products and services to customers and clients;
(c) Manage our ongoing relationship with customers, clients and others;
(d) Conduct marketing and research, including (i) to contact you to participate in surveys, (ii) to send you
information about sponsored events, promotions and contests (and to conduct and administer such promotions that you may participate in, such as sweepstakes), or (ii) to send you information about products or services that may be of interest to you.
(e) Meet legal and regulatory requirements; and
(f) Such other purposes consistent with these purposes. 

The personal information we ask for will depend upon which services you may obtain or which promotions you may decide to participate in.

How We Collect and Use Personal Information
We only collect, use and disclose Personal Information for purposes that would be considered reasonable in the circumstances and only such information as is required for the purposes of providing services or information to our customers, clients and franchisees.  We use only fair and lawful methods to collect Personal Information.

Our use of Personal Information is limited to the purposes described in this Policy and, except as described in this Policy, we do not otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information we have obtained. 

When We May Disclose Your Personal Information
We may disclose your Personal Information to individuals or organizations:
a) Who are our advisers, business partners, or service providers; and
b) Who are, or may be, involved in (i) a transfer of all or part of the assets or business of our company or a franchise company (ii) maintaining, reviewing and developing our business systems, procedures and infrastructure including testing or upgrading our computer systems; or (iii) a corporate re-organization of our company. 

We may also disclose your Personal Information to our parent company, Regis Corporation, and its subsidiaries and affiliates in order to carry out the purposes described in this Policy. In the event sensitive Personal Information is provided to us, we will not disclose such Personal Information unless it is required in order to provide a customer, client, or franchisee with our services.Where we disclose Personal Information to our business partners, we will require those business partners to use such information solely in furtherance of the business purpose for which we have engaged the business partner and to have appropriate safeguards for the protection of that Personal Information.

Where we disclose Personal Information to organizations that perform services on our behalf, we will require those service providers to use such information solely for the purposes of providing services to us, our prospective or existing customers, clients, franchisees or the person concerned and to have appropriate safeguards for the protection of that Personal Information.  

Where Personal Information may be subject to transfer to another organization in contemplation of a merger, sale of our company’s assets or our company’s business units or change of ownership of all or part of our company, we will do this only if the parties have entered into an agreement under which the collection, use and disclosure of the information (including any Personal Information) is restricted to those purposes that relate to the business transaction, including a determination of whether or not to proceed with the business transaction, and is to be used by the parties to carry out and complete the business transaction.  

Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where we are obliged to disclose information without consent.  Such circumstances may include: 
a) Where required by law or by order or requirement of a court, administrative agency or governmental tribunal;
b) Where we believe, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
c) Where it is necessary to establish or collect monies owing to us;
d) Where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain; or
e) Where the information is public. 

Where obliged or permitted to disclose information without consent, we will not disclose more information than is required. 

Consent
Unless permitted by law, no Personal Information is collected, without first obtaining the consent of the individual concerned to the collection, use and dissemination of that information. However, we may seek consent to use and disclose Personal Information after it has been collected in those cases where we wish to use the information for a new or different purpose where the individual concerned has not already consented to such a use of their personal information. 

By providing Personal Information to us you agree and consent that we may collect, use and disclose your Personal Information in accordance with this Policy.  In addition, where appropriate, specific authorizations or consents may be obtained from time to time.  

In most cases and subject to legal and contractual restrictions, you are free to refuse or withdraw your consent at any time upon reasonable, advance notice.  For example, you may always opt-out of our mailing lists.  It should be noted that in certain circumstances, services can only be offered if you provide Personal Information to us. Consequently, if you choose not provide us with any required Personal Information, we may not be able to offer you the services requested. We will inform you of the consequences of the withdrawal of consent.  

The Accuracy And Retention Of Personal Information
We endeavour to ensure that any Personal Information provided and in our possession is as accurate, current and complete as necessary for the purposes for which we use that information. If we become aware that Personal Information is inaccurate, incomplete or out of date, we will revise the Personal Information and, if necessary, use our best efforts to inform third parties which were provided with inaccurate information so that those third parties may also correct their records.

We keep your Personal Information only as long as it is required for the reasons it was collected.  The length of time we retain information varies, depending on the service and the nature of the information.  This period may extend beyond the end of a person’s relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. 

When your Personal Information is no longer required for our purposes, we have procedures to destroy, delete, erase or convert it into an anonymous form.

Currently, the principal places where we hold Personal Information are in the cities of Mississauga, Ontario and Minneapolis, Minnesota  USA and places where off-site storage facilities may be located and places where our salons are located. 

Protection of Personal Information
We endeavour to maintain appropriate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This also applies to our disposal or destruction of Personal Information.

We further protect Personal Information by restricting access to it to those employees that the management of our company has determined need to know that information in order that we may provide our services. 

If any employee of our company misuses Personal Information, this will be considered as a serious offence for which disciplinary action may be taken, up to and including termination of employment.  If any individual or organization misuses Personal Information - provided for the purpose of providing services to or for our company - this will be considered a serious issue for which action may be taken, up to and including termination of any agreement between our company and that individual or organization. 

Access To Your Personal Information
We permit the reasonable right of access and review of Personal Information held by us about an individual and will endeavour to provide the information in question within a reasonable time, generally no later than 30 days following the request. To guard against fraudulent requests for access, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or making corrections. 

We will provide information from our records in a form that is easy to understand. We reserve the right not to change any Personal Information but will append any alternative text the individual concerned believes to be appropriate.  

We reserve the right to decline to provide access to Personal Information where the information requested: 

a) Would disclose (i) Personal Information, including opinions, about another individual or about a deceased individual; or (ii) trade secrets or other business confidential information that may harm us or the competitive position of a third party;
b) Would interfere with contractual or other negotiations of our company or a third party;
c) Is subject to solicitor-client, litigation or other legal privilege;
d) Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information;
e) Does not exist, is not held, or cannot be found by us;
f) Could reasonably result in (i) serious harm to the treatment or recovery of the individual concerned, (ii) serious emotional harm to the individual concerned or another individual, or (iii) serious bodily harm to another individual; 
g) May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by law to perform such functions; or
h) May be withheld or is requested to be withheld under applicable legislation.

Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.

We will not charge you for verifying or correcting your information, however, to the extent permitted by applicable law, there may be a minimal charge imposed if you need a copy of records.  

Web Site
Our Web servers track general information about visitors such as their domain name, time of visit, IP address and which pages are being accessed. This information is used only in aggregate form, to better serve visitors by helping us to:
a)  Manage our site;
b)  Diagnose any technical problems; and
c)  Improve the content of our Websites. 

In browsing the Web, you will encounter a technology known as “cookies”.  “Cookies” are files or pieces of information that may be stored in a computer’s hard drive when an individual visits a Website. Most Internet browsers are initially set to accept cookies. If you do not wish to accept cookies, you can set yours to refuse cookies or to alert you when cookies are being sent. "Session" cookies are temporary bits of information that are erased once a visitor exits its Web browser window or otherwise turn its computer off. Session cookies are used to improve navigation on Websites and to collect aggregate statistical information. Our Websites use session cookies. 

"Persistent" cookies are more permanent bits of information that are placed on the hard drive of a visitor’s computer and stays there unless it is deleted. Persistent cookies store information on a visitor’s computer for a number of purposes, such as retrieving certain information previously provided (e.g., passwords), helping to determine what areas of the Website visitors find most valuable, and customizing the Website based on visitor preferences. Our Websites use persistent cookies. 

We do not share Personal Information obtained through cookies with any third parties. 

We have no control over the content of third party Web sites that individuals may access through hyperlinks at our Web site.  We encourage everyone to read the privacy policy of every Web site they visit. 

Resolving Your Privacy Concerns
In the event of questions about: (i) access to your Personal Information;  (ii) our collection, use, management or disclosure of Personal Information; or (iii) this Policy; please contact our Privacy Officer by sending an e-mail to departmentcs@regiscorp.com or calling 1-877-857-2070. 

We will investigate all complaints and if a complaint is justified, we will take all reasonable steps to resolve the issue.
 

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