Overview
Steelay ("Steelay," "we," "us," or "our") is designed with privacy at its core. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use our mobile and web applications (the "Services").
By accessing or using Steelay, you agree to the practices described in this Privacy Policy.
Information We Collect
We may collect the following categories of information:
Account Information
- Name
- Email address — used as the primary account identifier for authentication, account recovery, support communications, and transactional communications.
- Phone number — used for SMS verification, account recovery, fraud prevention, enabling certain application features, and associating stylist-created client records with verified client accounts.
User Content
- Photos and videos uploaded to the platform
- Style notes and descriptions
- Hair profiles and preferences
- Salon, stylist, and service location information
Media uploaded through the Services is private by default. Media uploaded by a stylist may become visible to the associated client after the client successfully claims their Style Passport. Public sharing of media through community features or stylist portfolios will occur only when explicitly enabled by the user or stylist through available platform features.
Location and Service Information
- City
- ZIP code
- Salon and business location information, including data selected through third-party services such as Google Maps.
City, ZIP code, and service location information are used to associate users with salons and style entries, improve platform functionality, understand geographic usage trends, support product development, and generate aggregated and de-identified business insights.
We do not collect precise geolocation data (e.g., GPS coordinates) unless explicitly stated and authorized.
Usage and Device Data
- Device type and operating system
- Persistent device and account identifiers used to recognize returning users, authenticate accounts, and operate the Services.
- App usage activity, feature usage, onboarding progress, session information, and analytics events.
- Limited application error events used to improve the reliability, stability, and performance of the Services.
Device Permissions
To provide core functionality, Steelay may request access to:
- Camera — to capture photos for style entries
- Photo Library — to upload existing images
These permissions are only used when initiated by the user and are not accessed passively.
How We Use Your Information
We use your information to:
- Provide, operate, and maintain the Services.
- Enable the creation, management, and sharing of Style Passports and style entries.
- Associate stylist-created client records with verified client accounts, enabling clients to securely claim and access their Style Passport.
- Improve functionality, usability, and user experience through analysis of feature usage, onboarding progress, and product interaction data.
- Personalize content and recommendations where applicable.
- Ensure security, prevent fraud and misuse, and protect the integrity of the Services.
Data Sharing and Third-Party Services
Steelay does not sell personal data in identifiable form.
We may share information with trusted third-party service providers strictly as necessary to operate the platform, including:
- Cloud hosting and infrastructure providers
- SMS verification providers (e.g., Telnyx)
- Analytics providers used to measure product usage and improve the Services.
- Mapping and location services (e.g., Google Maps)
These providers are contractually obligated to process data only on our behalf and in accordance with applicable laws.
We may also disclose information if required by law or legal process, or to protect the rights, safety, or integrity of Steelay and its users.
Use of Third-Party Location Services
Steelay uses third-party mapping and location services, including Google Maps, to allow users to search for and associate salon and service locations with their entries.
When using these features:
- Location data is selected by the user and not collected through real-time tracking
- Salon names, addresses, and place identifiers may be retrieved and stored
- Use of these services is subject to the respective provider's terms and privacy policies
Steelay does not use these services to track user location in real time.
Cookies and Tracking Technologies
Steelay and our third-party service providers may use cookies, software development kits (SDKs), local storage, pixels, and similar technologies to operate and improve the Services, analyze usage patterns, maintain user sessions, and support security features.
You may control cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Services.
Steelay does not use advertising technologies, behavioral tracking technologies, or third-party tracking mechanisms to profile users across apps, websites, or services for targeted advertising purposes. If this changes, this policy will be updated accordingly.
Steelay does not currently respond to "Do Not Track" browser signals, as no industry-wide standard for interpreting such signals has been adopted. We will revisit this position as standards evolve.
Aggregated and De-Identified Data
Steelay may collect, generate, and use aggregated and de-identified data derived from user activity, content, service locations, and general geographic information (such as city and ZIP code), provided that such data:
- Does not identify and cannot reasonably be used to identify an individual or specific business
- Is aggregated or processed to prevent linkage to any specific user, stylist, client, or salon
- Is maintained using commercially reasonable safeguards against re-identification
We may use, analyze, commercialize, license, disclose, publish, and otherwise exploit this data for lawful purposes including analytics, trend analysis, product development, research, benchmarking, and commercial partnerships. Steelay does not attempt to re-identify aggregated or de-identified data. Aggregated and De-Identified Data, derivative analytics, statistical models, trend analyses, benchmarking information, and other insights generated by Steelay are not considered Personal Information or User Content and remain the exclusive property of Steelay.
Stylist-Created Client Records
Stylists may create client records within the Services using information provided by or about their clients, including names, phone numbers, service history, photographs, and related styling information, for the purpose of documenting services and facilitating future account claiming.
If a client later creates or verifies a Steelay account using the corresponding verified phone number, the associated Style Passport may be linked to that account.
Steelay is designed to facilitate this association while maintaining appropriate access controls and privacy protections.
Data Security
We implement commercially reasonable administrative, technical, and organizational safeguards designed to protect your information. However, no system can be guaranteed to be completely secure.
In the event of a data breach affecting personal information, Steelay will notify affected individuals and, where required, the Florida Department of Legal Affairs within 30 days of discovery, in accordance with the Florida Information Protection Act (Fla. Stat. § 501.171).
Data Retention
We retain personal information only as long as necessary to provide the Services, comply with legal obligations, and resolve disputes and enforce agreements. Users may request deletion of their data at any time.
Your Rights
You may:
- Access your personal data
- Request correction of inaccurate data
- Request deletion of your data
To submit a request, contact us at hello@steelay.style.
California Privacy Rights (CCPA / CPRA)
If you are a California resident, you have the following rights:
- Right to Know — request details about the personal data we collect, use, and share
- Right to Delete — request deletion of your personal data, subject to certain exceptions
- Right to Correct — request correction of inaccurate personal data we hold about you
- Right to Opt-Out — opt out of the sale or sharing of personal data (Steelay does not sell personal data in identifiable form)
- Right to Limit Use of Sensitive Personal Information — request that we limit the use of sensitive personal information to what is necessary to provide the Services
- Right to Non-Discrimination — we will not discriminate against you for exercising any of the above rights
To exercise your rights, contact: hello@steelay.style
International Users
Steelay is operated in the United States. If you access the Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States or other countries where our service providers operate. Data protection laws in these countries may differ from those in your country of residence.
By using the Services, you acknowledge and consent to the transfer of your information to the United States and the processing of your data in accordance with this Privacy Policy.
Children's Privacy
Steelay is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If such data is identified, it will be deleted promptly. Parents or guardians may contact us at hello@steelay.style.
Business Transfers
In the event of a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction. Any such transfer will remain subject to the commitments made in this Privacy Policy.
Changes to This Policy
We may update this Privacy Policy from time to time. Updates will be posted with a revised effective date. For material changes — such as new data uses or changes to sharing practices — we will notify you via email to the address associated with your account or through a prominent in-app notice prior to the change taking effect. Continued use of the Services after the effective date constitutes acceptance of the updated policy.
Contact
For privacy-related inquiries or requests: hello@steelay.style