Privacy Policy
WELLBIZ BRANDS, INC. PRIVACY POLICY
For California Residents: Limit the Use of My Sensitive Personal Information
For California Residents: Do Not Sell Or Share My Personal Information
For California Residents: CCPA & CPRA Opt-Out Choice
Non-California Residents: Opt-Out
Last Revised January 9, 2023
This Privacy Policy explains our information practices, defines a user’s (“you” or “your”) privacy options and describes how your information is collected and used by WellBiz Brands, Inc. and its Affiliates, Affiliated Brands and subsidiaries (collectively, “us”, “we” “our” or “WBB”). This Privacy Policy covers all of WB websites, mobile phone applications, the website(s) at https://wellbizbrands.com, and specifically includes any branded website(s) or mobile phone applications that have been developed for any of our Affiliates or Affiliated Brands (the “WB Sites”). The WB Sites include, but are not limited to, 1) drybarshops.com, 2) elementsmassage.com, 3) amazinglashstudio.com, 4) fitnesstogether.com, 5) radiantwaxing.com, and 6) theglowpass.com. For the purposes of this policy, the term “Affiliate” shall mean any entity, individual, firm, or corporation, directly or indirectly, through one or more intermediaries, controlling, controlled by, or under common control with WBB. The Amazing Lash Studio®, Drybar®, Radiant Waxing™, Fitness Together®, and Elements Massage® franchise systems and GlowPass™ brand are collectively referred to as the “Affiliated Brands”. Please note that franchisees of the Amazing Lash Studio, Drybar, Radiant Waxing, Fitness Together, and Elements Massage franchise systems (each a “Franchisee”) are each independent entities and their processing of information may be subject to their own privacy policies. For more information on how a specific Franchisee processes your information, please direct your request to the relevant Franchisee location.
By using or accessing the WB Sites and Affiliated Brands franchised locations sites, you agree to the collection and use of information in the manner described in this Privacy Policy. WBB shall have the right at any time and without prior notice, at its sole discretion, to revise this Privacy Policy. Such revisions and additions shall be effective immediately upon notice, which may be given by any means, including but not limited to posting the revised or additional terms on WB Sites. You are responsible for reviewing the WB Sites periodically for any modification to this Privacy Policy.
This Privacy Policy is part of our Terms of Service.. If you do not agree to the practices in this Privacy Policy and our Terms of Service, do not use or access the WB Sites.
This Privacy Policy applies to all information collected on the WB Sites and any information you provide to WBB, primarily Personal Information (as defined below), which deals with individuals, rather than organizations or businesses. “Personal Information” uniquely identifies an individual by combining information collected with other data.
This Privacy Policy does not apply to the online store and website located at www.thedrybar.com (“Drybar Products Online”), owned and operated by Drybar Products LLC, a Helen of Troy Ltd subsidiary. Please note that while we work closely with the foregoing parties and allow users to use their online accounts at Drybar Products Online, we are not the same company or affiliates, and their privacy policy located at www.thedrybar.com/privacy will govern the collection, use, and disclosure of your Personal Information in connection with Drybar Products Online.
WBB is committed to providing clients with exceptional service. As providing this service involves the collection, use, and disclosure of some Personal Information about you, protecting and ensuring the privacy of your Personal Information is one of WBB’s highest priorities. One of the ways we do that is to have this Privacy Policy, which tells you why and how we collect, use and disclose your Personal Information.
Because WBB is a U.S.-based company, the services are controlled and offered from locations in the United States. The data protection rules and rights of government access to your data in your state, province, or country may be different from those in the United States. WBB will continue to process your personal information as described in this Privacy Policy.
SECTION 1 – PERSONAL INFORMATION WE COLLECT
Personal Information You Provide To Us. Personal Information you may provide to us through the services offered by our Affiliated Brands franchised locations, and that may include:
- Information regarding potential COVID-19 exposure, such as your temperature and whether you have symptoms associated with or have been diagnosed with COVID-19.
- Contact data, including but not limited to your first and last name, email and mailing addresses, postal code, phone number, and social media aliases.
- Profile data, such as your username and password that you set to establish an online account with us, and other information you include in your account profile.
- Haircare preferences, such as your hair type, hair concerns, and the products and services you have received from Drybar Products Online or in a Drybar shop, and services you have received from a Drybar shop.
- Massage sessions, eyelash extension services, waxing services, personal training services preferences, products, gift cards, and other services you purchase in these locations or using the WB Sites.
- Communications that we exchange when you communicate with us, such as when you request support, contact us with questions or feedback, or complete our surveys.
- When you use WB Sites, content, such as comments, text, images, audio, video or other content you post to or provide through those sites.
- Appointment information, such as your past and upcoming appointment dates and locations and the services you have requested.
- Payment and transactional data, such as the information needed to complete your in-store orders and purchases (such as name and credit card information), information about your payment transactions, and your order and purchase history.
- Marketing data, such as your preferences for receiving communications about Affiliated Brands’ franchised locations products and services, activities, events, and publications; details about how you engage with our communications; and information you provide when you participate in an event, contest or promotion.
- Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third party sources. We may collect information about you from third party sources and may combine Personal Information we receive from you with Personal Information we obtain from those other sources, such as:
- Data providers, such as information services and data licensors.
- Public sources, such as public social media platforms.
- Business partners, such as joint marketing partners, licensors/licensees, joint venture partners and event co-sponsors.
- Affiliates and Affiliated Brands franchised locations for which you may also be a consumer.
Automatic collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on the WB Sites and other online sites and services, including:
- Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, internet service provider, the website you visited before browsing to our website, and general location information such as city, state or geographic area.
- Online activity data, such as what pages you visit, what products or files you view, referring/exit pages and the third-party sites that led you to our site or mobile application.
- Precise geolocation data, such as when you authorize our mobile application or your web browser to access your location.
Cookies and similar technologies. Some of our automatic data collection on the WB Sites is facilitated by:
- Cookies, which are text files that websites store about a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of tracking user activity and patterns, helping you navigate between pages efficiently, remembering your preferences and generally improving your browsing experience.
- Flash cookies, or locally-stored objects, which are used for purposes similar to cookies but allow storage of a larger amount of data.
- Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened or that certain content was viewed or clicked, typically to compile statistics about the usage of websites and the success of marketing campaigns.
- Software development kits, or SDKs, which are used to incorporate third party computer code into our application that allows the third party service providers or advertising partners to collect data directly from it for a variety of purposes, including to provide us with analytics regarding the use of the Drybar mobile application, to integrate with social media, add features or functionality to our app, or to facilitate online advertising.
Information about others. You may have the opportunity to share Personal Information about others with us, such as when you book an appointment for them through WB Sites, purchase a gift card for a third party, or refer friends or other contacts to WB Sites. When you share the Personal Information of others with us, you are responsible for ensuring you have their permission to do so.
Information from Drybar Products Online. As part of our integration with Drybar Products Online, they will provide us with certain Personal Information about you, such as profile data and contact data, including name, phone number, e-mail, and product purchase history relating to your shared account on the WB Sites and with Drybar Products Online, your marketing data, and certain transactional data relating to your online purchases.
SECTION 2 – HOW WE USE YOUR PERSONAL INFORMATION
We may use categories of information for business and commercial purposes such as:
- provide, operate and improve the WB Sites, such as when we or Affiliated Brands’ franchised locations use your Personal Information to schedule and confirm appointments with you and process your transactions for the blowouts services, massage sessions, eyelash extension services, waxing services, personal training services, products, gift cards, and other services you purchase in these locations or using the WB Sites;
- verify your identity;
- determine whether you may have, or have been exposed to, COVID-19
- prevent fraud and abuse
- identify your shopping preferences and your shopping activities;
- open and manage an account;
- deliver requested products and services or respond to questions;
- process a reservation, as well as provide services;
- enroll you in a program;
- send you Affiliated Brands’ franchise locations newsletters, coupons, updates, reminders, related email marketing, and other information;
- ensure a high standard of service to you;
- meet regulatory requirements;
- send SMS updates, appointment reminders, and special marketing promotions;
- promote Affiliated Brands’ franchised locations products or services to you;
- respond to your queries and communicate with you about the WB Sites, including by sending announcements, updates, security alerts, and support and administrative messages;
- to keep track of customer feedback, understand your needs and interests, and personalize your experience with the WB Sites and Affiliated Brands’ franchised locations communications; and
- improve customer service and provide support and maintenance for the WB Sites.
Research and development. We may use your Personal Information for research and development purposes, including to customize the data activities on the WB Sites, improve the online experience, and analyze and improve the data activities on the WB Sites and business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from Personal Information we collect. We make Personal Information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the data activities on the WB Sites and promote the business.
Marketing and advertising. We, our Affiliated Brands franchised locations and our third-party advertising partners may collect and use your Personal Information for marketing and advertising purposes:
- Direct Marketing. We may send you direct marketing communications as permitted by law, including but not limited to communications from our Affiliates and Affiliated Brands franchised locations for their respective products or services. You may opt-out of marketing communications as described below
- Interest-Based Advertising. We may contract with third-party advertising companies and social media companies to display ads on the WB Sites and other sites. These companies may use cookies and similar technologies to try to tailor the ads you see online to your interests based on your activity over time across the WB Sites and other sites or your interaction with Affiliated Brands’ email. These ads are known as “interest-based advertisements.” You can learn more about your choices for limiting interest-based advertising in the “Advertising choices” section below.
Compliance and Operations. We may use your Personal Information in the following circumstances:
- When the collection, use, or disclosure of Personal Information is permitted or required by law;
- In an emergency that threatens your life, health, or personal security;
- To comply with orders of public health authorities and related obligations;
- When the Personal Information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer or for auditing and other professional services;
- For the purposes of collecting a debt or to protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law;
- To prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
- If WBB, its Affiliates, or any Affiliated Brands is acquired or merged with another company, your information may be transferred to the new owners so that they may continue to service or sell products to you.
For other purposes. We may also use your Personal Information for other purposes described in this Privacy Policy or at the time we collect the information.
SECTION 3 – HOW WE SHARE YOUR PERSONAL INFORMATION
We may share your Personal Information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.
Other Users And The Public. If at any time the WB Sites offer any chat rooms, comments, notice board facilities, reviews, social media, newsgroups, etc., information that you post or make available may be collected by other users or the public. Please note that we cannot be responsible for other parties’ use of the Personal Information, which you may make available to such third parties through any chat room, comments, notice board, newsgroup, etc. on the WB Sites. Please be careful about what Personal Information you disclose in this way.
Affiliates. We may share your Personal Information with WBB’s corporate parents, subsidiaries, Affiliated Brands, franchised locations, third-party vendors (including but not limited to Helen of Troy and Drybar Products Online), and Affiliates, for purposes consistent with this Privacy Policy.
Service Providers. We may share your Personal Information with unrelated companies and individuals that provide services on our behalf or help us operate the WB Sites or our or our Affiliated Brand’s franchised business (such as customer support, hosting, payment processing, appointment booking, analytics, email delivery, marketing, and database management services). These third parties may use your Personal Information only as authorized under our contracts with them.
Business Partners. We may share your Personal Information with our business partners, such as joint marketing partners, licensors/licensees, joint venture partners and event co-sponsors. We will also share your information with Drybar Products Online and Helen of Troy. This information will only be shared as necessary to provide you services in accordance with this Privacy Policy. The purpose of this sharing is to facilitate providing joint services, internal statistics, strategic decision-making, and, will be shared consistent with your marketing preferences.
Advertising Partners. We may sometimes share your Personal Information with our advertising partners, and may enable such partners to collect information directly via the WB Sites for the purposes described in the Marketing and Advertising section, above.
Professional Advisors. We may share your Personal Information with professional advisors, such as lawyers, bankers, financial advisors, accountants, auditors and insurers, where necessary in the course of the professional services that they render to us.
Authorities And Others. We may share your Personal Information with law enforcement, government authorities, and private parties, when we believe in good faith it is necessary or appropriate as further described in the “Compliance and Operations” section above.
Business Transferees. We may sell, transfer or otherwise share some or all of our business or assets, including your Personal Information, with relevant participants in business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, WBB, our parents, subsidiaries, or Affiliates, and Affiliated Brands (including, in connection with a bankruptcy or similar proceedings).
For Other Purposes. We may also share your Personal Information for other purposes described in this Privacy Policy or with your consent.
SECTION 4 – YOUR CHOICES
In this section, we describe the rights and choices available to all users.
Opt Out Of Marketing Communications. If you no longer wish to receive marketing-related emails from us, you may opt out by clicking the “unsubscribe” option in the email message, informing us at [email protected], or mailing us at: Legal Dept / 1890 Wynkoop St., Unit 1, Denver CO 80202, call (866) 969-5666. You may continue to receive service-related and other non-marketing emails
If you consent to receive text messages, you may receive auto-dialed appointment confirmations and reminders in addition to marketing or promotional texts. You may receive SMS or MMS messages. Message and data rates may apply, check with your cellular or data carrier for information. Appointment confirmations and reminders will be based on the number of appointments you make. Consent to receive text messages is not required/not a condition for purchase of products or services. You can opt out of receiving text messages. To stop receiving text messages, reply STOP to any text message you receive.
Choosing Not To Share Your Personal Information. Subject to certain exceptions (e.g., the Personal Information is necessary to provide the services or product, or where we must use your Personal Information to perform a legal obligation), you can choose not to share your Personal Information with us. If you do not provide this Personal Information when requested, it may restrict us or our Affiliated Brands’ franchised locations’ ability to provide a particular service or product. If so, we will explain the situation to assist you in making the decision by telling you what information you must provide to receive the services by designating it as required at the time of collection or through other appropriate means.
Cookies & Browser Web Storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the WB Sites and third-party websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the WB Sites may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.
Location Data. Users of our mobile application also have the choice whether to allow us to access your precise location data. Your device settings may provide the ability for you to revoke our ability to access location data. Most web browsers also have the choice to allow us to access your precise location data. To disable this feature, please check your browser settings.
Advertising Choices. Some of the business partners that collect information about users’ activities on or through the WB Sites may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.
Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.
If you choose to opt out of targeted advertisements, you will still see advertisements online, but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
SECTION 5 – SECURITY
The security of your Personal Information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the Personal Information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your Personal Information.
SECTION 6 – OTHER SITES, MOBILE APPLICATIONS AND SERVICES
The WB Sites may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your Personal Information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
SECTION 7 – CHILDREN
The WB Sites are not intended for use by children under 13 years of age, and we do not intentionally collect Personal Information from children under 13. If we learn that we have collected Personal Information from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.
SECTION 8 – CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may be updated from time to time for any reason. If we make material changes to this Privacy Policy we will notify you by posting the new Privacy Policy on the WB Sites and changing the “Last Updated” date above. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail or another manner through the WB Sties. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your continued use of the WB Sites after the posting of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.
Please direct any questions or comments to: Legal Dept / 1890 Wynkoop St., Unit 1, Denver CO 80202, [email protected], or call (866) 969-5666.
SECTION 10 – IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS
This section applies only to California residents. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”) but does not include information exempted from the scope of the CCPA or CPRA .
Personal Information That We Collect, Use And Share. We have created a table below which summarizes the Personal Information we have collected by reference to the categories specified in the CCPA, during the preceding 12 months.
| Category of Personal Information (PI) as specified in the CCPA (Definitions are available here) | Details of PI we collect(See the “Personal Information We Collect” section above for more details) |
| Identifiers |
|
| Financial Information |
|
| Commercial Information |
|
| Internet or Network Information |
|
| Online Identifiers |
|
| Geolocation data |
|
| Inferences | May be derived from your:
|
| Physical Description |
|
| Sensory Information |
|
| Protected Classification Characteristics | Other than your COVID-19 screening information, we do not intentionally collect this information but it may be revealed in other information we collect, such as profile data, haircare preferences and your content. |
The sources from which we collect this Personal Information are described in the section above titled “Personal Information We Collect” and the categories of third parties with whom we share Personal Information are described in the section above titled “How We Share Your Personal Information”. The business and commercial purposes for our collection, use, and disclosure of Personal Information are described in the section above titled “How We Use Your Personal Information.”
We disclose each of the categories of Personal Information for a business purpose (as defined in the CCPA). In addition, the CCPA and CPRA requires us to disclose which categories of Personal Information we share with third parties for “valuable consideration.” We share the following categories of Personal Information with the advertising partners and business partners described in the section above titled “How We Share Your Personal Information”: Identifiers, commercial information, internet or network activity, online identifiers, inferences, and physical description. You may opt-out of this sharing by following the instructions below.
Your California Privacy Rights. If you are a California resident, you can request to exercise your privacy rights as detailed within CCPA and CPRA and listed below.
- Opt-Out Of Sales. If we “sell” your Personal Information, you can opt-out. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your Personal Information covered by that law with third parties for their direct marketing purposes.
- Deletion. You can ask WBB to delete the Personal Information that we have collected about you.
- Access. You can ask WBB for a copy of the Personal Information that we have collected about you.
- Correction. You have the right to request corrections of any inaccuracies in your Personal Information.
- Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with whom we share Personal Information.
- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
- Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
- You are entitled to exercise your CCPA and CPRA privacy rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our services.
How To Exercise Your Rights. You may request to exercise your California privacy rights described above as follows:
- Right to information, access, correction, and deletion.
- You can click https://www.drybarshops.com/privacy-policy/
- Call us at (866) 969-5666
- If either of these don’t work, send us an email to [email protected].
- The CCPA and CPRA allow you to limit the sale and sharing of your Personal Information. We do not sell any of your Personal Information for monetary consideration. We share your Personal Information for limited purposes as specified in this Privacy Policy. You have the right to opt-out of the “sale” of your Personal Information. You can request to opt-out of the “sale” of your Personal Information by emailing us at [email protected] or by clicking here: Do Not Sell or Share My Personal Information
Limit The Use Or Disclosure Of Sensitive Personal Information.
- The CCPA and CPRA also allow you to limit the use or disclosure of Sensitive Personal Information (“SPI”) such as Covid 19 screening information. We collect SPI to protect our clients and our employees. We do not collect SPI for general marketing or any other purpose and this information is not shared with any third party.
WBB is happy to process your privacy enactment request, once we have confirmed your identity and validated that you reside in California. As part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government-issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
If you are somehow affiliated to WBB, in that perhaps you are an employee, vendor, contractor, or hold any other position for or within the company, and you reside in California, feel free to enact your CCPA rights using the methods detailed in this section. Unfortunately, we won’t be able to send you any human resource related information or other information in accordance with applicable law (examples may be; payroll, PTO, benefits, contract information), but we will process your privacy enactment request in the same manner that we would for any other California Resident. Requesting to exercise your CCPA and CPRA privacy rights won’t change the affiliation you have with WBB in any way.
Your California privacy rights are not absolute, and in certain cases we may decline your request as permitted by law. For example, WBB may reject privacy enactment requests if there is any suspected malice, including any which may be deceptive, fraudulent, illegal or pose a security threat. WBB may also reject requests related to legal or criminal matters, or if they’re related to any in-progress transactions or purchases.
SECTION 11 – YOUR STATE PRIVACY RIGHTS
State consumer privacy laws may provide their residents with additional rights regarding our use of their Personal Information.
Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:
- Confirm whether we process their Personal Information.
- Access and delete certain Personal Information.
- Data portability.
- Opt-out of personal data processing for targeted advertising and sales.
Colorado, Connecticut, and Virginia also provide their state residents with rights to:
- Correct inaccuracies in their Personal Information, taking into account the information’s nature processing purpose.
- Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.
To exercise any of these rights please do so by either
Calling us at: (866) 969-5666 or
Submit a request to : [email protected]
SECTION 12 – DATA RETENTION
We will retain your Personal Information only for as long as is necessary for the purposes set forth in this Privacy Policy.
Identifiers which may include a real name, postal address, telephone number, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers will be retained for as long as services are performed and thereafter for record keeping purposes or as otherwise required by law or legal process.
Commercial information which may include records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies will be retained for as long as services are performed and thereafter for record keeping purposes or as otherwise required by law or legal process.
Internet or other similar network activity may include browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement will be retained only for as long as services are performed and for record keeping purposes or as otherwise required by law or legal process.