Our Commitment to Privacy

Last Updated and Effective as of: September 8, 2026

 

1. Scope of This Policy

Your privacy is important to us. This Privacy Policy ("Policy") explains how The Dessy Group ("we," "us," "our," or "Company") collects, uses, discloses, and protects personal information in connection with the website located at dessy.com (the "Web site"), and describes the choices and rights you have regarding that information.

This Policy applies only to the Web site. It does not apply to any other website, application, product, or service provided by us, our affiliates, or our clients, unless this Policy is expressly posted there. It also does not apply to information collected offline or through channels other than the Web site.

By accessing or using the Web site, you acknowledge that you have read and understood this Policy. Your use of the Web site is governed by this Policy and our Terms of Use, which are incorporated by reference. If you do not agree with this Policy or our Terms of Use, do not access or use the Web site.

2. Residents Outside the United States

The Web site is intended for use by residents of the United States. 

The Web site is maintained in the United States. If you access it from another jurisdiction, you understand that your information will be transferred to, stored, and processed in the United States, where data-protection laws may differ from those where you reside. You freely and specifically consent to this transfer and processing as described in this Policy, and you understand that data stored in the United States may be subject to lawful requests by courts or law-enforcement authorities in the United States.

3. Categories of Personal Information We Collect

We collect the following categories of personal information (as those categories are defined under the California Consumer Privacy Act ("CCPA"), as amended by the CPRA, and comparable state laws). We do not necessarily collect all of these about every individual.

Category

Examples

Collected?

Identifiers

Name, email address, postal/shipping address, phone number, account username, IP address, device identifiers

Yes

Customer records / commercial information

Payment information, billing address, order history, products purchased or considered

Yes

Internet or network activity

Browsing and search history on the Web site, interactions with the Web site and ads, clickstream data

Yes

Geolocation data

General (non-precise) location derived from IP address

Yes

Audio/electronic information

Chat transcripts, communications with our customer service or stylist team

Yes

Inferences

Preferences and characteristics drawn from the above to personalize your experience

Yes

Sensitive personal information

Account log-in with password; payment card number with any required security or access code

As needed; see Sec. 8

 

We collect this information directly from you (e.g., when you order, inquire about, or purchase a product, use our chat or stylist service, register for a service, or otherwise contact us); automatically as you use the Web site (see Section 6); and from third parties such as service providers, advertising and analytics partners, payment processors, and data vendors. When we combine information received from other sources with information collected through the Web site, we treat the combined information in accordance with this Policy.

We do not collect personal information from you unless you voluntarily provide it or it is collected automatically through the technologies described in Section 6.

4. How We Use Personal Information

We use personal information for the following business and commercial purposes:

·       To process, fulfill, and deliver the orders and transactions you place, including through payment processors and shipping providers;

·       To provide the specific products and services you request (such as connecting you with a retailer or our stylist service);

·       To respond to your inquiries, questions, and customer-service requests;

·       To send you communications, including newsletters, promotions, order updates, and service notices (see Section 12 for your opt-out choices);

·       To personalize your experience and to deliver relevant content and advertising, including interest-based advertising (see Section 6);

·       To operate, maintain, analyze, secure, and improve the Web site and our products and services;

·       To detect, investigate, and prevent fraud, security incidents, harassment, and other unlawful activity, and to enforce our Terms of Use and this Policy;

·       To comply with legal obligations and respond to lawful requests; and

·       For any other purpose disclosed to you at the time we collect the information or to which you consent.

We will use your personal information only as described in this Policy, unless you specifically consent to another use at the time of collection or thereafter.

5. How We Disclose Personal Information

We do not sell your personal information, and we do not disclose your personal information to third parties for their own direct-marketing purposes. We may disclose personal information only as follows:

·       Service providers and contractors. We disclose personal information to vendors and subcontractors that perform services for us (for example, payment processing, shipping and fulfillment, hosting, analytics, email delivery, and customer support). These parties are permitted to use the information only to perform services for us and are not authorized to use it for their own purposes.

·       Advertising and analytics partners. We may disclose certain online-activity and device information to advertising and analytics partners to deliver and measure advertising, as described in Section 6. Depending on how these technologies are configured, such disclosures may constitute "sharing" for cross-context behavioral advertising under certain state laws, even though no money is exchanged. You may opt out — see Section 7.

·       Legal and protective disclosures. We may disclose personal information where required by law, regulation, subpoena, court order, or other legal process; to investigate or address suspected fraud, harassment, or violations of any law, rule, regulation, or of our Terms of Use or this Policy; and to protect the rights, property, or safety of the Company, our users, or others.

·       Corporate transactions. We may transfer personal information in connection with, or during negotiations of, any merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets or of the division associated with the information.

·       With your consent. We may disclose personal information for any other purpose with your consent or at your direction.

We may disclose de-identified, aggregated, or anonymized information — which does not identify you — to any party without restriction.

6. Cookies, Tracking Technologies, Interest-Based Advertising, and Analytics

Cookies and similar technologies. "Cookies" are small files placed on your device to facilitate and enhance your interaction with a website. We and our third-party service providers, advertisers, and business partners may use cookies and similar technologies (such as clear GIFs/pixels, web beacons, tags, and SDKs) to operate and personalize the Web site, remember your preferences, analyze usage, and deliver advertising. These technologies may collect information such as your IP address, device type, and general location.

We use session cookies (which expire when you close your browser) and persistent cookies (which remain on your device for up to one (1) year) to recognize you and to understand and target the interests of users in order to enhance our services. You can stop, restrict, or delete cookies by adjusting your browser settings; if you do, some features of the Web site may not function properly. We do not use cookies to retrieve personal information from your device without your knowledge. See Section 12 for opt-out options and Section 7 for opt-out preference signals.

Interest-based (behavioral) advertising. We, and third-party vendors, may use information about your activity to deliver advertising tailored to your interests, including on other websites and services. For example, if you view a particular product, you may later see an advertisement for that product elsewhere. We do not receive monetary payment for this activity, but it may constitute "sharing" under certain state privacy laws. You can opt out as described in Sections 7 and 12. We adhere to the Digital Advertising Alliance ("DAA") Self-Regulatory Principles for Online Behavioral Advertising.

Cross-device linking. We and our third-party vendors may use information to associate multiple devices with you, using deterministic data and/or probabilistic techniques, in order to deliver and measure advertising across your devices. See Section 12 to limit certain cross-device uses.

Clickstream data. As you use the internet, information is generated about the websites you visit ("clickstream data"), which may indicate your device and browser type and the site from which you linked to the Web site. We use clickstream data on an aggregated and anonymized basis to understand how visitors use the Web site and to improve it; this use is not intended to contain personal information.

Analytics. We use analytics providers to help us measure and analyze Web site traffic and usage.

7. Your Privacy Rights and Choices

Depending on your state of residence and applicable law, you may have some or all of the following rights regarding your personal information:

·       Right to know / access the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of third parties to whom we disclose it;

·       Right to correct inaccurate personal information;

·       Right to delete personal information we have collected from you, subject to legal exceptions;

·       Right to data portability — to obtain a copy of your personal information in a portable, machine-readable format;

·       Right to opt out of the "sale" or "sharing" of your personal information and of targeted/cross-context behavioral advertising;

·       Right to limit the use and disclosure of sensitive personal information (see Section 8);

·       Right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects, where applicable;

·       Right to non-discrimination — we will not discriminate against you for exercising any of these rights; and

·       Right to appeal a denial of your request, where provided by your state’s law (see below).

We will honor these rights to the extent applicable law requires.

Do Not Sell or Share My Personal Information

We do not sell your personal information. To opt out of the "sharing" of your personal information for targeted/cross-context behavioral advertising, you may: use the "Do Not Sell or Share My Personal Information" link on the Web site; email us at support@dessy.com; and/or follow the interest-based advertising opt-out steps in Section 12.

Opt-Out Preference Signals (Global Privacy Control)

Where required by applicable law, we recognize and honor opt-out preference signals, including the Global Privacy Control ("GPC"), as a valid request to opt out of the sharing of personal information for the browser or device from which the signal is sent. Because such signals are browser- and device-specific, you must enable them on each browser and device you wish to have opted out.

How to Exercise Your Rights

To submit a request, contact us at support@dessy.com or call 800-444-8304. To request deletion specifically, you may also email stylist@dessy.com.

We will verify your request by matching the information you provide with information in our records, and we may request additional information reasonably necessary to verify your identity. You may use an authorized agent to submit a request on your behalf; we may require the agent to provide proof of authorization and may require you to verify your own identity directly.

We will respond to verifiable requests within the timeframe required by applicable law (generally 45 days, extendable by an additional period where permitted, with notice to you). There is generally no charge, though we may charge a reasonable fee or decline to act on requests that are manifestly unfounded, excessive, or repetitive, as permitted by law.

Right to Appeal

If we decline to take action on your request and your state’s law provides an appeal right, you may appeal by replying to our response or emailing support@dessy.com with the subject line "Privacy Appeal." We will respond to your appeal within the period required by your state’s law. If your appeal is denied, you may contact your state Attorney General or applicable regulator.

State-Specific Notes

The specific rights available to you depend on your state of residence and on whether the applicable law applies to us. California residents have the applicable rights described above. Because we do not disclose personal information to third parties for those third parties’ own direct-marketing purposes, no separate "Shine the Light" disclosure list applies; if you have questions, email support@dessy.com. Residents of Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, and other states with comprehensive privacy laws have the applicable access, correction, deletion, portability, opt-out, and (where provided) appeal rights described above, to the extent the relevant law applies to us.

8. Sensitive Personal Information

We collect a limited amount of sensitive personal information — specifically, account log-in credentials in combination with a password, and payment-card information in combination with any required security or access code — solely as necessary to create and secure your account and to process your transactions. We do not use or disclose sensitive personal information for purposes other than those permitted under applicable law (such as performing services, processing transactions, security, and fraud prevention), and we do not use it to infer characteristics about you. Where a right to limit the use of sensitive personal information applies, you may exercise it by contacting support@dessy.com.

9. Data Retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, including to provide our products and services, to satisfy legal, accounting, tax, and reporting requirements, to resolve disputes, to prevent fraud and abuse, and to enforce our agreements. To determine the appropriate retention period, 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 requirements. Even after we delete personal information, we may continue to retain and use de-identified, aggregated, or anonymized data. We are not liable for disclosures of your data resulting from errors or the unauthorized acts of third parties.

10. Security

The security of your personal information is important to us. We maintain reasonable administrative, technical, and physical safeguards designed to protect the personal information we collect, and we limit access to personal information to those employees and service providers who need it to perform their duties. We use encryption to help protect the transmission of certain information. However, no method of transmission over the internet or method of electronic storage is completely secure. Because of the inherently open nature of the internet, we cannot and do not guarantee that communications between you and us, or information stored on the Web site or our servers, will be free from unauthorized access by third parties such as hackers, and your use of the Web site constitutes your acknowledgment and assumption of this risk. For more information on protecting your privacy, you may visit www.ftc.gov/privacy.

11. Children’s Privacy

The Web site is not directed to children, and we do not knowingly collect personal information from children under 13 in violation of the Children’s Online Privacy Protection Act ("COPPA"). If we learn that we have collected personal information from a child under 13 (or such other age as applicable law protects), we will use reasonable efforts to delete it. In addition, consistent with applicable state law, we do not knowingly sell or share, or process for targeted advertising, the personal information of consumers we know to be under the age of 16 without the required opt-in consent. If you believe a child has provided us with personal information, please contact us at support@dessy.com.

12. Your Choices and Opt-Out Processes

Opting out of marketing messages. To unsubscribe from our marketing emails, use the unsubscribe link in any such email or send your request to support@dessy.com. We will process opt-out requests within a reasonable time. We may still send you non-promotional, transactional messages (such as order confirmations).

Opting out of cookies. You can stop, restrict, or delete cookies through your browser settings. More information is available at www.allaboutcookies.org. Disabling cookies may affect the functionality of the Web site. Cookies are not used by us to automatically retrieve personal information from your device without your knowledge.

Opting out of interest-based advertising. You can opt out of interest-based advertising from participating companies through the DAA at www.aboutads.info/consumers. After opting out, you may still see generic (non-tailored) advertising. Cookie-based opt-outs are specific to each browser and device, so you must opt out separately on each one.

Opting out of sharing and honoring GPC. See Section 7.

13. Communications With The Dessy Group; Feedback

By providing your email address, you consent to receive emails from us, including information you have requested and information about our products and services. We will not provide your email address to another party to promote that party’s products or services directly to you without your consent.

You agree that we are free to use any ideas, concepts, know-how, suggestions, or techniques contained in any communication you send to us, without attribution or compensation and for any purpose, including developing, manufacturing, and marketing products and services.

14. Public Forums and Third-Party Services

Public disclosures. Personal information you voluntarily post or transmit in any publicly accessible forum — such as a blog, chat room, review, or social-media platform — may be viewed and used by others without restriction. We cannot control such uses, and by using these features you assume the risk that your information may be viewed and used by third parties for any purpose.

Third-party links and social networking. The Web site may contain links to, or integrations with, third-party websites, plug-ins, applications, and social-networking services. Clicking those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third parties and are not responsible for their privacy practices or content. We provide access to such services merely as an accommodation and rely, as you do, on those services to operate properly and fairly. We encourage you to review the privacy policy of every website and service you use.

15. Terms of Use; Arbitration and Limitation of Liability

Your use of the Web site is also subject to our Terms of Use, which are incorporated into this Policy by reference and which contain important provisions governing your relationship with us, including (where applicable) binding arbitration, a class-action waiver, disclaimers of warranties, and limitations of liability. Nothing in this Policy creates any private right of action beyond that expressly provided by applicable law.

16. Changes to This Policy

We reserve the right, at our discretion, to change, modify, add, or remove portions of this Policy at any time. If we intend to use previously collected personal information in a manner that materially differs from the Policy in effect when the information was collected, we will post the change here (and provide any additional notice or choice required by law). We will update the "Last Updated" date above when we make changes. Your continued use of the Web site after we post changes constitutes your acceptance of those changes.

17. Contact Us

For questions or concerns relating to privacy, contact us at:

The Dessy Group
8 West 38th Street, 4th Floor
New York, NY 10018
Email: support@dessy.com
Phone: 800-444-8304