PRIVACY POLICY

Effective Date: November 29, 2025

City Lights Beauty + Experiential Agency LLC (“CLBA,” “we,” “our,” or “us”) is committed to protecting the privacy, confidentiality, and security of all individuals who engage with our services. This Privacy Policy describes how we collect, use, disclose, retain, and safeguard information in accordance with applicable United States federal law, Florida law (including the Florida Information Protection Act “FIPA”), industry standards, and recognized international privacy principles.

By accessing or using our websites, booking services, signing contracts, submitting forms, or engaging with CLBA in any capacity, you acknowledge and agree to this Privacy Policy. If you do not agree, please discontinue use of all CLBA services immediately.

1. Scope

This Privacy Policy applies to all information collected by CLBA across all touchpoints, including but not limited to:

• Websites, landing pages, booking portals, CRM platforms, and mobile-responsive online services.
• On-location, on-site, virtual, and remote service delivery.
• Communications via email, SMS, phone, messaging apps, and social media platforms.
• Contractor, employee, intern, and vendor onboarding or engagement.
• Marketing campaigns, ad platforms, newsletters, referral links, affiliate programs, and lead-generation tools.
• Professional, corporate, government, entertainment, wedding, and experiential client engagements.

It applies to clients, prospective clients, contractors, staff, employees, business partners, website visitors, event organizers, and corporate or agency partners.

2. Information We Collect

A. Personal Information

Depending on your interaction with CLBA, we may collect:

Identity & Verification Data
Full name, date of birth, gender (optional), government ID, work authorizations, licenses, or credentials (for contractors/employees).

Contact Data
Email address, phone number, mailing address, billing address, emergency contact information.

Financial Data
Card details, bank account information, direct deposit information, and tax forms — all processed through secure, PCI-compliant third-party payment gateways. CLBA does not store full financial details.

Service & Engagement Data
Booking details, service preferences, communications, contracts signed, event information, questionnaires, notes, timelines, and feedback.

Photo & Media Data
Photos, videos, audio, or other media captured or voluntarily shared during services or events.

Employment & Contractor Data
Resumes, agreements, tax forms, background info, insurance documents, certifications, performance data, and direct deposit details.

User-Submitted Content
Testimonials, reviews, public comments, or materials voluntarily provided.

B. Non-Personal & Technical Information

• Device type, browser type, and operating system
• IP address, region, approximate geolocation (when allowed)
• Website activity, clicks, time on site, referral URLs
• Cookies, pixels, tags, marketing identifiers
• Analytics from tools such as Google Analytics, Meta Pixel, TikTok Pixel, and CRM reporting systems
• Security logs and fraud-prevention identifiers

3. Methods of Collection

CLBA collects information through:

• Direct interactions: forms, contracts, bookings, payments, inquiries, phone calls, and emails
• Automated technologies: cookies, CRM tracking, analytics tools, session replay tools, and ad pixels
• Third-party integrations: payment processors, scheduling systems, cloud storage, marketing tools, website hosts
• Employment & contractor onboarding: compliance, legal, insurance, and tax documentation
• Event participation: photography, videography, and client interaction data

4. Purposes of Data Use

CLBA processes information for legitimate business, contractual, and legal purposes, including to:

• Fulfill services, bookings, contracts, and event obligations
• Manage scheduling, staffing, logistics, and location-based service delivery
• Process payments, issue invoices, and maintain financial compliance
• Provide customer support and service updates
• Verify contractor credentials and maintain compliance standards
• Improve website functionality, user experience, and internal operations
• Conduct marketing, retargeting, and advertising campaigns (opt-out available)
• Prevent fraud, unauthorized access, or misuse of services
• Enforce contracts, resolve disputes, or comply with subpoenas or legal investigations
• Maintain regulatory, tax, and insurance compliance

5. Legal Basis for Processing

Where applicable, CLBA relies on:

• User consent
• Contractual necessity
• Legal or regulatory compliance
• Legitimate business interests such as security, analytics, fraud prevention, and business optimization

6. Sharing of Information

CLBA does not sell personal data. We may share information only with:

• Service providers: cloud hosting, email platforms, payment processors, CRM, IT vendors, legal advisors, insurance providers, accountants
• Contractors and staff performing your booked service (limited information provided as necessary)
• Corporate or event partners who require relevant details to deliver contracted services
• Government, law enforcement, or regulatory authorities where legally required
• Successors or acquirers in the event of a business sale, merger, restructuring, or asset transfer

All third-party service providers must follow strict confidentiality and data-protection obligations.

7. International Data Transfers

Some third-party technology providers may process data outside the United States. CLBA requires that any international data transfers meet acceptable data-protection standards, including contractual safeguards or privacy frameworks equivalent to U.S. requirements.

8. Cookies & Advertising Technologies

CLBA uses cookies, pixels, and related technologies to:

• Personalize website experience
• Track engagement
• Improve analytics
• Deliver targeted advertising or retargeting

Users may adjust cookie preferences in browser settings. Blocking cookies may limit site functionality.

9. Data Retention

CLBA retains information only as long as necessary for business, legal, and compliance purposes:

• Client + event records: minimum 7 years
• Contractor/employee data: minimum 7 years post-termination
• Financial records: minimum 7 years
• Communications, forms, and contracts: up to 7 years
• Marketing data: until user unsubscribes or requests deletion
• Aggregated or anonymized data may be retained indefinitely

10. Security Measures

CLBA maintains administrative, physical, and technical safeguards, including:

• SSL encryption
• Encrypted data transmission and storage
• Role-based access control
• Regular audits and security monitoring
• Fraud and threat detection tools
• Contractor and staff confidentiality and non-disclosure obligations
• Response procedures aligned with FIPA

No system is entirely immune to risks, but CLBA follows industry standards to minimize them.

11. Data Breach Notification

If a breach occurs, CLBA will:

• Notify affected individuals within legally required timeframes
• Provide details of the breach, data involved, and remediation steps
• Notify regulatory or law enforcement authorities when required

12. Your Rights

You may request:

• Access to information we hold
• Corrections to inaccurate data
• Deletion (where legally permissible)
• Limitation of certain processing activities
• Opt-out of any marketing communications

Requests must be submitted to [email protected]. Identification verification may be required.

13. Children’s Privacy

CLBA does not knowingly collect information from individuals under age 13. Any data discovered to belong to a minor will be deleted immediately.

14. Employee & Contractor Data

Employee, freelancer, and contractor information is collected for:

• Identity verification
• Background or credential checks (when applicable)
• Payment processing
• Insurance and compliance
• Tax reporting
• Scheduling and staffing for events

This data is handled with strict confidentiality and stored securely.

15. Artificial Intelligence & Automated Processing

CLBA may use AI-driven tools, chatbots, or automation systems for customer support or operational enhancements. All AI tools operate under human oversight, and no major decisions are made solely by automated systems without human review.

16. Third-Party Links

Our websites may contain links to third-party sites. CLBA is not responsible for their privacy practices. Users should review external policies independently.

17. Dispute Resolution

This Privacy Policy is governed by the laws of the State of Florida.

Any dispute involving privacy, data, website usage, or service interactions shall be resolved exclusively through binding arbitration in Pinellas County, Florida, except where prohibited by law.

18. Changes to this Policy

CLBA may update this Privacy Policy at any time. Updates will be posted with a new “Effective Date.” Continued use of CLBA services constitutes acceptance of any changes.

19. Contact Information

City Lights Beauty + Experiential Agency LLC
St. Petersburg, Florida
Email: [email protected]
Phone: 813-945-6386
Website: citylightsmakeup.com