your california privacy rights

This privacy policy was last updated: March 8, 2011

This a web site operated by Sally Beauty Supply LLC (sometimes "Sally", "we" or "us"). Please also read our Terms of Use.

Beginning January 1, 2005, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2011 will receive information regarding 2010 sharing activities).

To obtain this information on behalf of BSG's U.S. operations please send an e-mail message to calprivacy@sallybeauty.com with "Request for California Privacy Information" on the subject line and in the body of your message. Be sure to provide in the request sufficient information to properly identify you and/or the members of your family. The information you provide in your request will be used only to identify the companies, if any, with whom we have shared your personal information. We will respond to you at your e-mail address with the requested information.

Please be aware that not all information sharing is covered by the California law referenced here, and only information on covered sharing will be included in our response.

For an explanation of our privacy practices, please review our privacy statement by clicking the "Privacy Policy" button on our home page or clicking here.

©2011 Sally Beauty Supply LLC. All rights reserved.

Sally Practices Consistent with California Anti-Slavery Law

In September 2010, the State of California approved a new law, the California Transparency in Supply Chains Act of 2010 (SB 657) designed to increase information made available by companies with regard to efforts to eradicate forced labor and human trafficking. Sally recognizes the problems and issues that slavery and human trafficking present and is committed to complying with the new law.

Sally is concerned about addressing the issues arising from slavery and human trafficking in our immediate supply chain. This includes strengthening and making appropriate workplace standards and policies for the manufacturers who make our products.

Our goal is to protect the human rights of workers involved in our supply chain, and to help individuals experience safe, fair and non-discriminatory working conditions. Sally is disclosing its specific actions in relation to five key points as each relates to Sally’s procurement:

Number 1: Conduct verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by a third party.

Number 2: Audit suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit.

Number 3: Requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

Number 4: Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.

Number 5: Provides company employees and management who have direct responsibility for supply chain management with training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.

The following are Sally actions related to each key point described in the Act for procurement of private label products:

Disclosure Number 1: Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by a third party.

Sally evaluates and addresses human rights issues as part of our commitment to fair labor practices within our supply chain. The verification process is more robust for suppliers of Sally’s private-label products, but in all cases Sally seeks to have its contractors covenant to comply with all applicable laws against slavery and human trafficking. When considering new factory partners and manufacturers in a new country for its private-label products, Sally vets it for political stability and port safety, known labor issues, safety for Sally employees and travel, and other factors. This process is handled and verified internally and does not involve third party audits.

Disclosure Number 2: Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit.

Sally’s manufacturing agreement terms and conditions for its private label products provide Sally with the right to audit a supplier’s legal compliance, which includes the right to audit for compliance with antislavery and anti- human trafficking laws. The right to conduct audits is not a part of the standard terms and conditions for other goods. In general, In general an audit would not be independent and unannounced, although Sally would have the option to enlist specialized assistance as needed.

Disclosure Number 3: Requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

Sally recognizes the importance of protecting the human rights of workers who produce the materials for our products and accordingly requires supplier compliance with all applicable laws. Suppliers are obligated to comply with all laws and regulations, but although compliance with such laws is part of the general compliance obligation, there is no specific requirement for direct suppliers to provide certification that materials incorporated into products comply with laws regarding slavery and human trafficking.

Disclosure Number 4: Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.

Sally considers fair labor practices an important part of human rights. To date, there have been no known violations related to slavery or trafficking in any of our supplier facilities.

Sally’s approach to fair labor violations focuses on monitoring with the goal of establishing compliance in the workplace environment. In the event that a case of human trafficking or slavery would be detected in Sally supply chain, Sally has an escalation process in place contractually and has the ability to terminate any supplier who remains in noncompliance after failing to cure a notified breach.

Disclosure Number 5: Provides company employees and management who have direct responsibility for supply chain management with training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.

Designated managers with responsibility for human resources or other compliance will receive training as determined from time to be time to be appropriate and necessary on human trafficking and slavery issues.

Conclusion

Sally is committed to upholding human rights as we conduct our business. We will update the disclosures to reflect Sally’s experience on preventing and addressing potential human rights violations in our supply chain, including in the areas of antislavery and anti-human trafficking.