Privacy Policy

EXC Luxury operates a technology marketplace designed to connect customers (“Customers”) with independent beauty and personal-care professionals (“Stylists” or “Providers”).

By accessing or using the Platform, you acknowledge the practices described in this Privacy Policy.

1. Information We Collect

Depending on how you use EXC Luxury, we may collect the following categories of information.

A. Account and Contact Information

We may collect:

• Full name
• Email address
• Telephone number
• Account username or identifier
• Password or authentication credentials in secured or encrypted form
• Profile photograph
• Preferred language
• Account preferences
• Communication preferences.

B. Customer and Booking Information

For Customers, we may collect information necessary to facilitate services, including:

• Requested services
• Appointment date and time
• Service preferences
• Appointment history
• Preferred Stylists
• Service addresses
• Location information
• Ratings and reviews
• Membership or rewards information
• Cancellation and booking history
• Communications relating to appointments
• Photographs or other content voluntarily uploaded through the Platform.

C. Special Event Information

Certain cosmetology or specialty services may only be available for on-location booking when the requested service is being performed in connection with a qualifying Special Event under applicable Florida law.

When a Customer selects the Special Event booking option, EXC may collect information including:

• Type of event
• Event name or description
• Event start and end dates
• Event location
• Customer's role in the event
• The relationship between the requested beauty service and the event
• Whether services will be provided only to identified event participants rather than the general public
• Customer declarations or certifications concerning the event
• Other information reasonably necessary to determine booking eligibility or maintain compliance records.

EXC may use and retain this information to facilitate bookings, evaluate service eligibility, maintain compliance records, resolve disputes, respond to regulatory inquiries, prevent misuse of the Platform, and comply with applicable law.

D. Stylist and Provider Information

For Stylists, EXC may collect:

• Legal name
• Contact information
• Profile information and biography
• Professional photographs and videos
• Portfolio materials
• Services offered
• Pricing information
• Availability and schedule
• Service areas
• Professional licenses, registrations, certifications, and expiration dates
• Government-issued identification where required for identity verification
• Information necessary for identity verification, KYC, background checks, or onboarding
• Insurance information where applicable
• Ratings and reviews
• Booking and service history
• Earnings, payment, payout, and transaction information
• Tax-related information where required by law.

EXC may use third-party providers to conduct identity verification, KYC, background screening, professional credential verification, payment processing, or similar functions.

2. Location Information

With appropriate device permissions, EXC may collect precise or approximate geolocation information from Customers and Stylists to:

• Identify available Stylists near a Customer
• Calculate travel distances
• Determine applicable travel charges
• Determine whether a requested service is within a Stylist's service area
• Facilitate Customer-Stylist matching
• Support navigation and service fulfillment
• Help prevent fraud or misuse
• Improve marketplace operations.

Customers may also provide a service or Special Event address manually.

Users may manage device location permissions through their device settings. Certain Platform features may not function properly if location access is disabled.

3. Payment and Transaction Information

EXC may collect information relating to:

• Service charges
• Platform or service fees
• Travel fees
• Tips
• Taxes
• Membership payments
• Refunds
• Credits
• Rewards
• Promotional offers
• Stylist payouts.

Payment card information may be collected and processed by third-party payment processors. EXC intends to limit its direct storage of complete payment-card information.

4. Photos, Videos and User Content

Stylists may upload photographs, videos, portfolios, profile images, and other content demonstrating their work.

Customers may also be permitted to upload photographs or other information where necessary to communicate service preferences.

Users represent that they possess the necessary rights and permissions for content submitted to EXC.

EXC may display Stylist profile and portfolio content within the Platform for purposes of promoting the Stylist's services and facilitating Customer selection.

EXC will not intentionally use private Customer photographs for public advertising without appropriate authorization.

5. Device and Technical Information

EXC may automatically collect information including:

• IP address
• Device type
• Operating system
• Application version
• Device identifiers
• Browser information
• Login activity
• Usage information
• Crash and diagnostic information
• Application interactions
• Security and fraud signals.

EXC may use cookies, SDKs, analytics technologies, and similar tools where applicable.

6. How We Use Information

EXC may use information to:

• Create and maintain accounts
• Authenticate users
• Connect Customers with Stylists
• Process and manage appointments
• Determine booking and service eligibility
• Administer Special Event bookings
• Maintain records relating to Special Event declarations
• Verify Stylist identities and professional credentials
• Calculate distance and travel fees
• Process payments and Stylist payouts
• Administer memberships, rewards, promotions, credits, or gift cards
• Provide Customer support
• Send transactional communications
• Prevent fraud, misuse, and unauthorized transactions
• Investigate complaints and disputes
• Maintain legal and compliance records
• Analyze Platform performance
• Improve EXC products and services
• Personalize the user experience
• Recommend services or Stylists
• Enforce EXC agreements and policies
• Respond to regulatory or governmental inquiries
• Protect Customers, Stylists, EXC, and the public.

7. How We Share Information

Customer–Stylist Sharing

When a booking occurs, EXC may provide the selected Stylist with information reasonably necessary to evaluate and perform the requested service.

For a Special Event booking, this may include relevant event information supplied by the Customer so that the Stylist can determine whether the appointment can appropriately and lawfully be accepted.

Customers may receive information regarding Stylists, including profile, portfolio, ratings, services, credentials, availability, and other relevant information.

Service Providers

EXC may share information with vendors providing services such as:

• Cloud hosting and storage
• Payment processing
• Identity verification
• KYC
• Background screening
• Analytics
• Mapping and geolocation
• Customer communications
• Email and SMS
• Application infrastructure
• Fraud prevention
• Cybersecurity
• Customer support.

Legal and Regulatory Disclosures

EXC may disclose information when reasonably necessary to:

• Comply with applicable law
• Respond to subpoenas, court orders, regulatory requests, or governmental inquiries
• Investigate fraud or unlawful activity
• Enforce agreements
• Protect Customers, Stylists, EXC, or others
• Establish, exercise, or defend legal claims.

Business Transactions

Information may be transferred in connection with a merger, acquisition, financing, restructuring, sale of assets, or similar corporate transaction, subject to applicable law.

8. Cloud Storage and Processing

EXC may use cloud infrastructure, including Amazon Web Services (“AWS”), and other technology providers to host and process information.

EXC will use commercially reasonable administrative, technical, and organizational safeguards appropriate to the nature of the information processed.

9. Data Security

EXC uses reasonable measures designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

These measures may include:

• Encryption
• Authentication and access controls
• Role-based administrative access
• Secure cloud infrastructure
• Monitoring and logging
• Restricted access to sensitive information
• Security testing.

No electronic system can be guaranteed to be completely secure.

Users are responsible for protecting their login credentials and should promptly notify EXC if they believe their account has been compromised.

10. Data Retention

EXC retains information for as long as reasonably necessary to:

• Provide the Platform
• Complete transactions
• Maintain booking and Special Event records
• Resolve disputes
• Prevent fraud
• Maintain financial and business records
• Comply with legal and regulatory requirements
• Establish or defend legal claims.

Information no longer reasonably required will be deleted, anonymized, or otherwise handled according to EXC's retention practices and applicable law.

11. Privacy Choices and Requests

Subject to applicable law, users may request:

• Access to certain personal information
• Correction of inaccurate information
• Deletion of certain information
• A copy of certain information
• Withdrawal of certain permissions or consents.

Certain information may need to be retained for legal, regulatory, transaction, fraud-prevention, safety, or dispute-resolution purposes.

Requests may be submitted to:

12. Marketing Communications

Users may opt out of promotional communications through the unsubscribe mechanism provided.

Opting out of marketing does not prevent EXC from sending necessary booking, transactional, safety, legal, or account communications.

13. Text Messages (SMS) and Email

This section explains which text messages and emails EXC sends, why we send them, and the choices you have.

Text Messages (SMS)

EXC sends text messages only through our “EXC Luxury Account Verification” program, which delivers one-time verification codes from an EXC Luxury toll-free number. We send a code to your mobile number only when you request one in the EXC app, for example when you:

• Sign in to or create a Customer or Stylist account
• Request a new code
• Change the mobile number on your account
• Sign in to EXC administrative systems (authorized EXC personnel only)

We use these codes to confirm that you control the mobile number, to protect your account from unauthorized access, and to prevent fraud.

A typical message reads: “EXC Luxury: Your verification code is 123456. This code expires in 5 minutes.”

One message is sent per verification request, so frequency depends on your activity. EXC does not currently send marketing or promotional text messages. Message and data rates may apply.

Text messages are delivered through Amazon Web Services. Your mobile number is used to deliver these codes and to operate your account as described in this Privacy Policy. SMS terms are also set out in our Terms and Conditions.

We do not sell your mobile number or SMS consent, and we do not share them with third parties for their marketing or promotional purposes. Mobile numbers are shared only with service providers that help us deliver messages and operate the Platform, as described in this Privacy Policy.

You may opt out of text messages by replying STOP. Because verification codes are required to sign in and to confirm changes to your mobile number, opting out may prevent you from using those features. For help, contact us using the details in the Contact Us section below.

Email

EXC sends emails that relate to your account, your bookings and payments, and the security of the Platform, including:

• Verification codes to confirm your email address
• Welcome messages when an account is created
• Stylist onboarding updates, including registration and background-check fee receipts and account activation
• Service receipts and invoices after a completed appointment
• Membership purchase and renewal confirmations
• Stylist payout confirmations
• Notices that a Stylist is temporarily unable to receive new booking requests
• Account suspension, deactivation and deletion notices

We send these emails to confirm your identity, keep you informed about transactions and your account, provide records of payments, and meet our legal and compliance obligations. Emails are delivered through Amazon Web Services.

These are transactional and account communications, so they are sent even if you opt out of marketing. Where EXC sends promotional emails, you may opt out as described in Marketing Communications above.

14. Children

The Platform is not intended for independent use by individuals under 18.

Users must be at least 18 years old to create an independent EXC account unless EXC expressly provides another legally compliant mechanism.

15. Third-party Services

The Platform may integrate with third-party payment, mapping, identity-verification, analytics, communication, or other services.

Third parties acting independently maintain their own privacy practices.

16. Florida Privacy and Data Security

EXC will maintain privacy and security practices consistent with applicable Florida and federal law.

Nothing in this Privacy Policy limits privacy rights that cannot legally be waived.

17. Changes to This Privacy Policy

EXC may periodically update this Privacy Policy to reflect changes in the Platform, business practices, technology, or legal requirements.

Where required, EXC will provide additional notice or obtain consent.

18. Contact Us