Privacy Policy

Topcuts Inc.

Effective Date: September 1, 2026

Topcuts Inc. (“Topcuts,” “we,” “our,” or “us”) respects your privacy and is committed to protecting the personal information you provide when using our website. This Privacy Policy explains how we collect, use, disclose, safeguard, and retain your information, and outlines your rights under applicable law.

Scope of This Privacy Policy

This Privacy Policy applies to personal information we collect through www.topcuts.com (the “Website”), through the Topcuts Rewards loyalty program, and through email, text message, and other electronic communications between you and Topcuts, as well as other interactions where this Policy is provided or referenced. Information collected directly at Topcuts salon locations may be subject to additional privacy practices applicable to those in-person interactions.

This Privacy Policy is intended to explain our information practices in a transparent way. It describes how we handle personal information but does not by itself constitute your consent to those practices; where consent is required, we obtain it as described in Section 3.

1. Information We Collect

A. Information You Provide. The name, email address, phone number, and message details you submit through our Website contact form; and, if you choose to join Topcuts Rewards, information such as your name, phone number, email address, date of birth, preferred salon location, and marketing communication preferences. Enrollment in Topcuts Rewards is completed on a page hosted by our loyalty program provider (LoyaltySOS); information you submit during enrollment is collected through that provider on our behalf. LoyaltySOS may process personal information in accordance with its own privacy practices, in addition to the practices described in this Privacy Policy.

B. Automatically Collected Information. IP address, browser and device information, and Website usage data (such as pages visited, time spent, and referring URLs), collected through cookies and similar technologies, including Google Analytics, Google Tag Manager, Hotjar, the Meta (Facebook) Pixel, and Google Maps embedded on our salon location pages (subject to our cookie consent controls). See our Cookie Policy for details.

C. From Third Parties. We do not use business-visitor-identification or similar third-party data-matching services (for example, tools that match IP addresses to company or individual identities) on this Website.

D. Sensitive Personal Information. We do not generally seek to collect sensitive personal information through this Website. If any is submitted voluntarily (for example, in an open-text message), we handle it in accordance with this Policy and applicable law.

2. How We Use Personal Information

We use personal information to: respond to inquiries submitted through our Website; administer the Topcuts Rewards loyalty program, including managing member accounts, tracking rewards activity, and providing loyalty benefits; send Topcuts Rewards members promotional and marketing communications by email and text message — including a new-member offer, a birthday offer, and other periodic or ad hoc offers — where they have consented to receive them; deliver transactional messages relating to your Topcuts Rewards account (such as reward balance or redemption notices); improve Website functionality and performance; prevent fraud and maintain security; and comply with legal and regulatory obligations.

3. Consent

We collect, use, and disclose personal information with your consent, which we obtain at the point of collection and for the specific purposes described in this Privacy Policy. When you provide personal information through the Website — for example, through our contact form — you consent to our use of that information for the purpose for which you provided it, as described in Section 2; we seek your consent for any separate or secondary purpose at the relevant time. Consent for cookies and similar technologies is managed separately through our cookie consent banner (see our Cookie Policy). Consent to receive marketing communications is obtained separately during Topcuts Rewards enrollment, in accordance with Canada’s Anti-Spam Legislation (CASL). Where required by law, we will obtain additional consent before collecting, using, or disclosing sensitive personal information. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice; to withdraw consent to marketing communications, use the unsubscribe mechanism in the message or contact us as described in Section 15.

4. Disclosure of Personal Information

We do not sell personal information. We may disclose personal information for the legitimate business purposes described in this Policy — including operating our loyalty program, hosting and analyzing our Website, and meeting legal obligations — to:

our employees and stylists, for day-to-day salon and business operations;
LoyaltySOS, our third-party loyalty program provider, to administer Topcuts Rewards, manage member accounts, process rewards activity, maintain customer preferences, and send program-related and promotional communications on our behalf where you have provided consent. LoyaltySOS processes personal information according to our instructions, and we take reasonable steps to require LoyaltySOS to safeguard the information it processes on our behalf;
Render, the third-party platform used to host our Website;
Web3Forms, the third-party service that delivers messages submitted through our Website contact form to us;
Google (Google Analytics and Google Tag Manager), Meta Platforms, Inc. (Meta/Facebook Pixel), and Hotjar Ltd., each of which processes Website usage information under its own privacy policy and applicable data protection obligations, as described further in our Policy;Cookie
Google Maps (Google LLC), embedded on our salon location pages, which — where you have provided the applicable consent through our cookie consent banner — may collect device and usage information when you view or interact with an embedded map; and
legal or regulatory authorities, where required or permitted by law.

5. Cookies and Tracking Technologies

We use cookies and similar technologies to enable proper Website functionality, analyze Website traffic, and improve user experience. Please refer to our Cookie Policy for details on the categories of cookies and third-party tools used on this Website.

6. Cross-Border Data Transfers

Personal information collected through this Website may be transferred to, processed, and stored in countries other than Canada, including the United States, where certain third-party service providers (such as our analytics and website-behaviour providers) operate their systems and infrastructure. We take reasonable contractual and organizational steps to help ensure that personal information transferred to service providers in other jurisdictions is protected to a standard consistent with this Privacy Policy and applicable Canadian privacy law.

7. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes outlined in this Policy, including responding to inquiries, administering the loyalty program, complying with legal obligations, and resolving disputes. When personal information is no longer required, we take reasonable steps to securely delete, destroy, or anonymize it.

8. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect personal information. However, no system is completely secure, and we cannot guarantee absolute security.

9. Data Breach Notification

If we become aware of a breach of security safeguards involving personal information under our control that creates a real risk of significant harm to an individual, we will notify affected individuals and report the breach to the Office of the Privacy Commissioner of Canada, as required under the Personal Information Protection and Electronic Documents Act (PIPEDA). We will also notify any other organization or government institution where doing so may reduce the risk of harm resulting from the breach. We maintain records of all breaches of security safeguards involving personal information under our control for a minimum of 24 months, as required by law.

10. Third-Party Links

Our Website may contain links to external websites, including our loyalty program provider’s website. We are not responsible for the privacy practices of those sites, and we encourage you to review their privacy policies.

11. Children's Privacy

Our Website is not directed to children, and we do not knowingly collect personal information from children through this Website without the consent of a parent or guardian. Where a child does not have the capacity to understand the nature and consequences of providing their personal information, we treat consent from a parent or guardian as required to collect, use, or disclose that information, consistent with the meaningful consent standard under PIPEDA. This does not affect the in-salon provision of services to children accompanied by a parent or guardian.

12. Marketing Communications

Topcuts sends promotional and marketing communications to Topcuts Rewards members, including a new-member offer, a birthday offer, and other periodic or ad hoc offers. These communications are delivered by email and text message (SMS) and are administered on our behalf by LoyaltySOS. When you enroll in Topcuts Rewards on our loyalty provider’s hosted page, you may separately choose whether to receive promotional emails and promotional text messages. Consent to receive promotional communications is not required to join Topcuts Rewards.

We send these commercial electronic messages in accordance with Canada’s Anti-Spam Legislation (CASL). We send promotional emails and text messages only to individuals who have provided consent to receive those communications. Consent records are maintained through our loyalty program provider or other systems used to manage marketing preferences. Every message identifies Topcuts as the sender, provides a way to contact us, and includes an unsubscribe mechanism (for example, an unsubscribe link in emails, or a reply keyword such as “STOP” for text messages). You may withdraw your consent to marketing communications at any time, and we will give effect to your request within the time required by law.

Withdrawing your consent to marketing communications does not affect transactional messages that are necessary to administer your Topcuts Rewards account (for example, reward balance or redemption notices).

13. Your Privacy Rights

Subject to applicable law, you may have the right to access, correct, or delete your personal information, to request information about how your personal information has been used, and to withdraw consent for certain data practices where applicable.

13.1 Additional Rights for Canadian Residents (PIPEDA)

Canadian residents have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA), including the right to access the personal information we hold about you, to challenge its accuracy, and to withdraw consent, subject to legal or contractual restrictions. If you are not satisfied with our response to a privacy concern, you may contact the Office of the Privacy Commissioner of Canada.

14. Exercising Your Rights

To exercise your rights, please contact us at info@topcuts.com with the subject line “Privacy Request.” We may require you to verify your identity before processing your request. We will respond within 30 days of receiving your request, as required under PIPEDA, and will notify you if we require an extension permitted by law. We will not discriminate against you for exercising your privacy rights.

15. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. Any changes will be posted on this page with a revised effective date.

16. Contact Information