Privacy Policy

WHAT PERSONAL INFORMATION WE COLLECT

“Personal Information” is data that relates to you that can reasonably identify you as an individual, either on its own or in combination with other information. Personal Information does not include data that has been aggregated or de-identified, such that you can no longer be identified using means reasonably available to us or made available public through governmental agencies.

The chart below outlines the categories of Personal Information we collect, specific examples of such Personal Information, the purpose(s) of the collection, and the source(s) of the collection.

We may also receive information from other sources, including any information which you provide directly to us (for example, when you contact customer support or otherwise communicate with us) and combine that with information we collect through the Squire Services. For example:

• If you choose to link, create, or log in to your Squire account with a payment provider (e.g., Apple Pay) or social media service (e.g., Facebook), or if you engage with a separate application or website that uses our API (or whose API we use) (e.g., an Enterprise Branded App), we may receive information about you or your connections from that website or application.
• Enterprise Customers may provide us with a rating after providing services to you.
• If you also interact with the Squire Services in another capacity, for instance as an Enterprise Customer, we may combine or associate that information with information we have collected from you in your capacity as a Consumer User.

WHERE/HOW DO WE COLLECT PERSONAL INFORMATION

We collect Personal Information about you from:

• You. When you provide such information directly to us, and when Personal Information about you is automatically collected in connection with your use of Squire Services, including as described in our Cookies Policy. This can include, for example, information collected from your mobile device or internet browser when you interact with any Squire Service, such as our website. 
• Enterprise Customers. When Enterprise Customers upload your Personal Information to our platforms in connection with their use of the Squire Services. 
• Integrated Partners and Service Providers. We work with service providers who collect information on our behalf to provide services to us. We only allow our service providers to use your Personal Information in connection with the services they provide us.
• Third Party Applications. We collect information from you when you interact with us through other third-party applications, such as Facebook and Google, which may use our API to connect you to the Squire Services. 
• Advertising Partners. We work with companies that help us deliver, measure and analyze the effectiveness of our ads. These companies collect information about you when you interact with our ads on our platforms and on the websites where our ads are displayed.
• Data Brokers and Information Providers. We may collect information from data brokers and other information providers who may make your Personal Information available to us, as permitted by law.

HOW WE USE YOUR PERSONAL INFORMATION

Our use of the Personal Information we collect is required for us to provide Squire Services to you, including to:

• Provide, maintain, and improve the Squire Services, including, for example, to facilitate scheduling, payments, send receipts, provide products and services you request (and send related information), develop new features, provide customer support to Enterprise Customers and Consumer Users, develop safety features, authenticate users, and send product updates and administrative messages;
• Perform internal business operations, including, for example, to prevent fraud and abuse of the Squire Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;
• Send or facilitate communications either between you and Squire or you and an Enterprise Customer, such as appointment cancellation confirmations or other appointment status updates;
• Contact you about Squire Services, news, and events, offers, contests, sweepstakes or other promotions of Squire; or an Enterprise Customer may, using the Squire Services, contact you for similar marketing purposes, which may include SMS messages, email or push notifications to your mobile device;
• Personalize and improve the Squire Services, by providing appointment reminders, appointment date and time suggestions, recommend features, content, social connections, referrals, and advertisements; and
• Comply with any legal obligations and enforce our legal rights, such as, among other things, to exercise contractual rights, to comply with financial reporting obligations, court orders, warrants, or subpoenas in accordance with applicable law.

LEGAL BASES FOR COLLECTION AND PROCESSING

Certain jurisdictions require that we identify a legal basis or business purpose for our collection and processing of your Personal Information. This includes:

• Contract performance. This applies where your Personal Information is necessary to enter into or perform a contract with you.
• Legitimate Interest(s). This applies when the collection and processing of your Personal Information is done to achieve a legitimate interest for us and does not outweigh any prejudice to your rights. We rely on this basis, for example, when we:
  - Provide recommendations and information to improve the user experience;
  - Send you information or direct marketing materials relating to our products and services; or
  - Prevent fraud or ensure security of our network and systems.

• Your Consent. This applies when our collection and processing is based on your consent. In certain circumstances, your consent may be implied based on your continued use of our website or the Squire Services or submission of your Personal Information in order to receive Squire Services. 
• Legal claims. This applies where your Personal Information is necessary for us to defend, prosecute or make a claim against you, us or a third party.

In jurisdictions that designate parties as data controllers or business and processors or service providers, Squire is a data controller and a business within the meaning of applicable law with respect to the collection, use, and other processing of Personal Information. 

If you choose not to provide Personal Information that is reasonably required to provide any Squire Services, it may hinder Squire’s ability to provide the requested information or services.

SHARING OF PERSONAL INFORMATION

In limited circumstances, we may share your Personal Information for a business purpose, such as to provide and improve the Squire Services or as required by applicable law. In the preceding 12 months, we may have shared your Personal Information as follows:

• Among Squire. We may share your Personal Information across Squire businesses and affiliated entities to provide the Squire Services to you, for administrative purposes within Squire, or for data centralization and/or logistics purposes. 
• Between Consumer-Users and Enterprise Customers. As a Consumer-User using the Squire Services to interact with an Enterprise Customer, we share your Personal Information with the relevant Enterprise Customer to enable them to perform the services you request. Please note, we are not responsible for the privacy practices of our Enterprise Customers or their third-party service providers. Please contact the Enterprise Customer you interact with directly for more information on that Enterprise Customer’s privacy practices.
• Primary Enterprise Contact. Information on the utilization of the Squire Services by individuals affiliated with an Enterprise Customer may be shared with the Primary Enterprise Contact or the organization who purchased the Squire Services. Examples of such individuals are employees of the Enterprise Customer, or licensees/lessees of the Enterprise Customer (e.g., hair grooming professionals who rent grooming station within an Enterprise Customer’s establishment and have access to the Enterprise Customer’s Commander account). 
• Integrated Partners and Service Providers. We may share your Personal Information with our integrated partners and service providers who provide services for us and our Enterprise Customers as part of delivering or enhancing the Squire Services, such as payment processing services, order fulfillment, website hosting, customer relationship management services, email services, SMS services, auditing, financial services promotions or offerings such as debit card and/or loan services, and other similar partnerships and services.
• Third Party Applications. You may choose to share your Personal Information with other third-party applications or websites that integrate with our API (e.g., Google, Facebook, Instagram) to access certain Squire Services. We may share your Personal Information received from such third-party applications with relevant Enterprise Customers from which services you request, as well as back to the third-party applications from where your Personal Information originated. 
• Other Third Parties in Connection with a Corporate Transaction. We may disclose or share your Personal Information if we are involved with a purchase, sale, financing, transfer, or acquisition of all or a portion of a business or assets, such as in connection with a merger, or in the event of a bankruptcy reorganization or liquidation. 
• Other Parties as Necessary or as Required by Law. We may disclose your Personal information to other parties (i) to comply with our legal obligations, including with auditors, lawyers, CPAs, financial consultants, or other agents; (ii) to comply with applicable law or respond to a legal process or a request for cooperation by a government entity or law enforcement; (iii) to detect, limit, and prevent fraud, or verify and enforce compliance with the policies governing the Squire Services; (iv) to protect our rights, property, and safety or that of any of Squire’s companies or affiliates, partners or employees; (v) if we otherwise notify you and you consent to the sharing; (vi) and where otherwise required by applicable law. 

We do not sell your personal information for money; however, some laws broadly define “sale” or “sell”, and certain disclosure activities may, therefore, qualify even though we do not receive financial compensation for the exchange. For example, we share Personal Information with our analytics and marketing partners to gain insights into preferences about our products and services, and for sharing advertisements with you based on Personal Information we collect from your activities over time (also known as cross-contextual behavioral advertising or targeted advertising).

In the preceding 12 months, we have “sold” or “shared”, as those terms are broadly defined by law, the following categories of personal information:

We do not disclose or share your sensitive Personal Information for purposes than those already identified.

ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS

We may allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, and other technologies to identify your device when you visit our website and use the Squire Services, as well as when you visit other online sites and services. For more information about these technologies and service providers, please refer to our Cookies Policy.

DATA PROTECTION RIGHTS

Squire values your rights with respect to your Personal Information. Before responding to a request to exercise your rights, we may need additional information to verify your identity before providing a response. In accordance with applicable law, you may—depending on your residency—be entitled to some or all of the following:

• The right to information: You may have the right to request confirmation of whether we store, use, or share your Personal Information and be informed about with whim your Personal Information has been shared.
• The right to access: You may have the right to request copies of your Personal Information. Before providing such copies, Squire may be required to verify your Personal Information to ensure that we respond to only legitimate requests. 
• The right to rectification: You may have the right to change or modify your Personal Information that is out-of-date or incorrect. 
• The right to erasure: You may have the right to request erasure of your Personal Information held by Squire subject to certain exceptions as prescribed by applicable law.
• The right to restrict processing: You may have the right to restrict our use(s) of your Personal Information under certain circumstances as prescribed by applicable law.
• The right to data portability: You may have the right to request copies of your Personal Information in an electronic format and request that we send that Personal Information to you or another third party under certain circumstances as prescribed by applicable law.
• The right to object to processing or withdraw consent: You may have the right to object to our use(s) of your Personal Information or withdraw consent where you have given it.
• The right to opt-out. You may have the right to opt-out to the selling or sharing of your Personal Information, as those terms are defined under applicable law.  
• The right to avoid automated decision-making. You may have the right not to be subject to a decision based solely on automated processing, including profiling, if this has a legal or other significant effect on you as an individual subject to certain exceptions as prescribed by applicable law.

HOW TO EXERCISE YOUR RIGHTS

Squire will comply with an individual’s requests in accordance with applicable law. 

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. 

You can also designate an authorized agent to make a request on your behalf. If you use an authorized agent, please include written permission that you have designated that agent to make the request, or proof of the agent’s power of attorney. We may follow up with you to verify your identity before processing your authorized agent’s request. 

We will take reasonable steps to verify your identity prior to responding to your requests and—except as required by applicable law—can only honor verified requests. The verification steps will vary depending on the sensitivity of the Personal Information and whether you have an account with us. This process may require you to provide identifying Personal Information—such as your data of birth and last for digits of your government identification numbers—or to send us an email from the email address associated with your account. Please note that we cannot respond to your request or provide you with Personal Information if we cannot verify your identity, the identity of your authorized agent, or the authority of your authorized agent to make the request.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

You may exercise the above rights by emailing us at [email protected]. 

In addition, if you are in the European Economic Area or the United Kingdom, you have the right to lodge a complaint to your relevant data protection authority about our collection and use of your Personal Information. The data protection authority for the UK is the Information Commission’s Office – whose website is https://ico.org.uk/. Contact information for data protection authorities based in the European Economic Area, Switzerland, and certain non-European countries are available on the EU Commission’s website via the following link: https://edpb.europa.eu/about-edpb/about-edpb/members_en. 

OTHER CHOICES YOU HAVE

Account Information. You may correct your account information at any time by logging into your online or in-app account. If you wish to cancel your account, if you are an Enterprise Customer, please email us at [email protected], if you are a Consumer User, please email us at [email protected]. Please note that in some cases we may retain certain Personal Information about you as required by law, or for legitimate business purposes to the extent permitted by law; such information shall not be deleted or modified even upon your verified request. For instance, if you have a standing credit or debt on your account, or if we believe you have committed fraud or violated the policies governing the Squire Services, we may seek to resolve the issue before deleting your Personal Information.

Information About Platform Permissions. Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. These platforms may have different permission systems for obtaining your consent. For example, the iOS platform will alert you the first time the Squire app wants permission to access certain types of data and will let you consent (or not consent) to that request.

• Location Information. We request permission for our app’s collection of precise location from your device per the permission system used by your mobile operating system. If you initially permit the collection of this information, you can disable it at any time by changing the location settings on your mobile device. However, this will limit your ability to use certain features of the Squire Services. Additionally, disabling our app’s collection of precise location from your device will not limit our ability to derive approximate location from your IP address. 
• Contact Information. We may also seek permission for our app’s collection and syncing of contact information from your device per the permission system used by your mobile operating system. If you initially permit the collection of this information, users can later disable it by changing the contacts settings on your mobile device.

Marketing Communications. At times, we or our Enterprise Customers via the Squire Services may send you marketing and promotional information about products and services that may be of interest to you. With respect to marketing communications, you have many choices regarding the use of your Personal Information, as described below:

• Opting Out of Marketing Email Communications. Within each marketing-related email communication, we will provide a means to unsubscribe, for example, a hyperlink located at the end of each such email. You may also opt-out of receiving marketing-related email communications by sending us an email at [email protected] with a note requesting to opt-out. Note that Squire will continue to send transaction-related emails regarding any products or services purchased while utilizing the Squire Services even after you unsubscribed from marketing emails. We may also need to send you certain communications regarding the operation and administration of the Squire Services (e.g., updates to our Terms of Service or this Privacy Policy). Receipt of transactional messages is a condition to using the Squire Services. If you no longer desire to receive transaction-related messages, you must cease using the Squire Services and terminate all accounts with us.
• Opting Out of SMS Text Messages. Within each marketing related SMS communication, we will provide a means to unsubscribe. You may also opt-out of receiving marketing-related SMS text messages by sending us an email at [email protected] with a note requesting to opt-out. Note that Squire will continue to send transaction-related SMS text messages regarding any products or services purchased while utilizing the Squire Services even after you unsubscribed from marketing-related SMS text messages. Receipt of transactional messages is a condition to using the Squire Services. If you no longer desire to receive transaction-related messages, you must cease using the Squire Services and terminate all accounts with us.

SOCIAL SHARING FEATURES

The Squire Services may integrate with social sharing features and other related tools that let you share actions while using the Squire Services with other apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please note, we are not responsible for the privacy practices of those social sharing services. Please contact the relevant social sharing service for more information on how they handle your Personal Information and their privacy practices.

LINKS TO THIRD PARTY WEBSITES

Our websites and mobile applications may contain links to third party sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of third parties. We encourage you to review the privacy policy available for each third party with which you interact.

APPEALS (VIRGINIA RESIDENTS ONLY)

Residents of Virginia have the right to appeal a decision with regard to their privacy request. For example, you may appeal our decision to decline to take an action on a request. To exercise your right to an appeal, please send us an email at [email protected].

CALIFORNIA SHINE THE LIGHT DISCLOSURE

California law permits residents of California to request certain details about how their information is shared with third parties for their direct marketing purposes. However, please note that Squire does not share your Personal Information with third parties for their direct marketing purposes unless you provide us with consent to do so.

COOKIES

When you visit our websites or use our mobile applications provided as part of the Squire Services, we may collect information, including Personal Information, about you using cookies, web beacons, pixels, and other similar tracking technologies (collectively, “Cookies”). Cookies are small pieces of text sent by a website you visit. A cookie file is stored in your web browser and allows us or a third-party to recognize you in order to help us learn about your use of the Squire Services, make your next use or visit better or provide you with advertisement content tailored to your interests. Please see our Cookies Policy so you can learn more about how we may use Cookies.

INTERNATIONAL TRANSFERS OF INFORMATION

Personal Information provided to us may be transferred to, or accessed by, entities located around the world as described in this Privacy Policy. Some of these entities may be in countries that do not provide an equivalent level of protection for Personal Information as your home country.

We have put in place safeguards to provide adequate protection for transfers of Personal Information in accordance with applicable legal requirements. This includes obtaining written assurances from any third party given access to your data to require them to adopt standards that ensure an equivalent level of protection for data as that adopted by Squire. For more information on the appropriate safeguards in place or to request a copy of these safeguards, please contact us using the contact details listed in the How to Contact Us section below.

SECURITY, RETENTION, AND STORAGE OF PERSONAL INFORMATION

The security and confidentiality of your Personal Information matters to us. For this reason, Squire has physical, technical, and administrative controls in place to protect your Personal Information from unauthorized access, use and disclosure. Squire evaluates these safeguards on an ongoing basis to help minimize risks from new security threats as they become known.

However, the Internet is not a completely secure environment, and we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. 

CHILDREN UNDER 16

The Squire Services are not intended for children under 16 years of age. We do not knowingly collect Personal Information from children under 16. If you are under 16 years of age, please do not provide any Personal Information to us. If we learn that we have collected any Personal Information from a child under the age of 16 without verifiable parental consent, we will delete that information from our database as quickly as possible. If you believe that we may have collected information from a child under 16, please contact us at [email protected]. We are not liable for any damages that may result from a user’s misrepresentation of age. 

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your rights with respect to your Personal Information as granted under applicable law. Unless permitted by applicable law, we will not:

• Deny you any goods or services;
• Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. 

HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

We retain your personal information for the entire time that you keep your account open and active with us. Thereafter, we may retain your personal information:

• for as long as necessary to comply with any legal requirement;
• on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures; and
• for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies.

We may aggregate or otherwise render information anonymous in such a manner that you are no longer identifiable. In such situations, we may retain such aggregated or anonymous information indefinitely.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be amended at any time. If we make material changes in the way we collect, use, disclose, or otherwise process your Personal Information, or to this Privacy Policy, we will provide you notice through the Services or by some other means, such as email when appropriate. Where required to do so by law, Squire may seek your affirmative consent prior to any material changes to this Privacy Policy. Your continued use of the Services after such notice constitutes your consent to the changes. We encourage you to periodically review the Privacy Policy for the latest information on our privacy practices.