Privacy Policy


This Privacy Policy describes how Betty Dain Creation, LLC and its affiliated brands (including ColorTrak, Barber Strong, and Adama Beauty Co.) ("We," "us," and/or "our") handle personal data we collect through our websites and mobile applications (collectively, the "Sites") and offline in connection with the operation of our business. This Privacy Policy explains the types of personal data we collect and process, how we may use and share the data, and the choices that are available to you with respect to our handling of your data.


Information we collect directly from you

We collect the information you provide directly to us, such as when you create an account or make a purchase. The types of personal data we may collect directly from you include:

Basic Identifying Information
Including your full name, postal address, e-mail address, phone number, account name, username, or other similar identifiers.

Device Information and Other Unique Identifiers
Including device identifier, internet protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifier, or similar unique identifiers.

Internet or Other Network Activity
Including browsing or search history and information regarding your interactions with our Sites, emails, or advertisements.

Geolocation Data
Including your address.

Payment Information
Including credit or debit card numbers which are process by our third party payment processors.

Commercial Information
Including products you have purchased, transaction history, and related information including billing information and shipping information.

User Content
Including your communications with us and any other content you provide (such as photographs, images, videos, survey responses, comments, reviews, testimonials, and other content).

Inferences drawn from or created based on any of the information identified above.

Job Applicant Information
Including professional or employment-related information (such as education and employment history) and any other information you provide in connection with applying and interviewing for employment with us. If we retain you as an employee, this may include, among other things, your Social Security number or taxpayer ID.

Information about you through your use of our Sites

We may collect information about you and your use of the Sites, when you create or change your account or correspond with our service team.

Information we collect by automated means

When you visit our Sites, we collect certain information automatically. To collect this information, we may use cookies, web beacons, log files, and similar technologies. A "cookie" is a text file that websites send to a visitor's computer or other internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser. A "log file" tracks your actions on websites and may collect information related to your device, browser, internet service provider, and the time of your activity. A "web beacon," also known as a pixel tag or clear GIF, is used to transmit information back to a web server. We may also collect information about your online activities over time and across third-party websites. The information we collect automatically may include:

  • URLs that refer visitors to our Sites;
  • Search terms used to reach our Sites;
  • Details about the devices that are used to access our Sites (such as IP address, browser information, location information, device information, and operating system information);
  • Details about your interaction with our Sites (such as the date, time, length of stay, and specific pages accessed during your visits to our Sites, and which emails you may have opened); and
  • Usage information (such as the number and frequency of visitors to our Sites).


We use the information that we collect generally to fulfill any orders placed through our Sites (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this information to:

  • Communicate with you;
  • Screen our orders for potential risk or fraud; and
  • When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

 We also use information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Sites (for example, by generating analytics about how our customers browse and interact with our Sites, and to assess the success of our marketing and advertising campaigns).


We may share the information we collect:

  • With service providers and vendors that provider services for us or on our behalf;
  • With select partners. service providers, and vendors in connection with the provision of our Sites and products;
  • To comply with a legal or regulatory obligation, protect and defend our rights or property, protect the safety of our customers and the public, and protect against legal liability;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by a third party;
  • Between and among our current and future parents, subsidiaries, affiliates, and other companies under common control and ownership; and
    With your consent and at your direction. 

Restricting cookies

Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Sites.


Our Sites are not designed for children and we do not knowingly collect personal data from children. If you have reason to believe that a child has provided personal data to us, please contact us at and we will delete that information from our databases.


We are headquartered in the United States, and we currently only have operations and entities in the United States. If you provide information to us from another country, we may transfer your personal data to, or store or access it in, a jurisdiction that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.


We may provide links to third-party websites, services, and applications that are not operated or controlled by us. This Privacy Policy does not apply to third-party services, and we cannot take responsibility for the content, privacy policies, or practices of third-party services. We encourage you to review the privacy policies of any third-party service before providing any information to or through them.


Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the data was collected, and any other permissible, related purpose.


We may change this Privacy Policy from time to time. If we do so, we will post the updated policy on our sites and will indicate when the Privacy Policy was last revised. If we make any material changes, we will provide you with additional notice. You should periodically review our current Privacy Policy to stay informed of our personal data practices.


California law requires us to disclose the following additional information with respect to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of the privacy policy.

California Shine the Light
Customers who are residents of California may request information concerning the categories of personal information (if any) we disclose to third parties or affiliates for their direct marketing purposes. If you would like more information, please submit a written request to us at this address:

Betty Dain Creations, LLC 
9701 NW 112th Ave, Suite 10
Miami, FL 33178

Categories of Personal Information We Collect and Our Purposes for Collection and Use

You can find a list of the categories of personal information that we collect and the sources of such information in the "Information We Collect" section above. We collect and use personal information for the business or commercial purposes described in the "How We Use Your Information" section above.

Categories of Personal Information Disclosed and Categories of Recipients
We disclose the following categories of personal information for business or commercial purposes to the categories of recipients listed below:

  • We disclose Basic Identifying Information with businesses, service providers, and third parties, such as advertising networks, analytics and social media networks.
  • We disclose Device Information and Other Unique Identifiers with businesses, service providers, and third parties, such as advertising networks, analytics, and social media networks.
  • We disclose Internet or Other Network Activity with businesses, service providers, and third parties, such as advertising networks, analytics, and social media networks.
  • We disclose Geolocation Data with businesses, service providers, and third parties such as advertising networks, analytics, and social media.
  • We disclose Payment Information with businesses and service providers who process payments.
  • We disclose Commercial Information with businesses, service providers, and third parties, such as advertising networks, analytics, and social media networks.
  • We disclose Audio and Visual Information with businesses and service providers who help administer customer service and fraud or loss prevention services.
  • We disclose Inferences with businesses and service providers who help administer marketing and personalization.

For more information on how your information is disclosed, please see the "How We Share Your Information" section above, which provides more detail on our business partners, service providers and third parties. We may also need to disclose any of the above categories of information pursuant to legal process.  As stated in the "Data Retention" section above, we typically retain your personal information for the period necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law.

Categories of Information “Sold”

We do not sell your personal data for a monetary fee; however, some U.S. privacy laws define a “sale” very broadly such that it may include our sharing of your personal data with certain third parties if we receive anything of value in return.  In that regard, we share your personal data with certain third-party marketing partners and in exchange we receive the ability to market or offer our products and services through their websites and applications.  This may be considered a “sale” under some laws.

The personal data that may be shared or sold in this context is: your name; email address; other contact information; and information obtained through cookies about, for example, your location, the website that directed you to our Sites, how you navigate our Sites, and what purchases you make.  

Other than these third-party marketing partners, there are no other third parties to which we will sell your personal data.  

Do-Not-Track Features

Many web browsers and some mobile operating systems and mobile applications include a “do-not-track” feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  No uniform technology standard for recognizing and implementing do-not-track signals has been finalized and, as such, we do not currently respond to do not track browser signals or any other mechanism that automatically communicates your choice not to be tracked online.  We will update this Privacy Policy if that changes in the future.

Additional Privacy Rights

Right to Information.  On our Sites that enable account creation, you may view, modify, and in certain cases, download or delete, information collected about you by selecting "Access My Personal Data."  In addition, subject to certain limits, you may ask us to provide the following information: 

  1. The categories of personal information we collected about you;
  2. The categories of sources from which the personal information was collected;
  3. The business or commercial purpose for collecting the personal information;
  4. The categories of third parties with whom we shared the personal information;
  5. The specific pieces of personal information we collected about you; and
  6. Whether your personal information was sold or shared (“shared” in this context means sharing for the specific purpose of cross-context behavioral advertising) and, if so, the categories of personal information that was sold or shared, the categories of third parties to which your personal information was sold or shared, and the business purpose for the sale or sharing.

Right to Delete.  You also have the right to ask us to delete any personal information that we have collected about you, subject to certain limitations. We may deny your deletion request if the information is necessary for us or our service providers to, among other things, provide a product or service you requested, take actions reasonably anticipated in the context of our business relationship with you, perform a contract we have with you, detect and protect against security incidents or illegal activity, comply with a legal obligation, or exercise a right provided for by law. 

Right to Opt Out of Sale or Sharing.  Certain states provide residents with the right to opt out of the sale of personal information.  If you are a resident of a state that provides such right, you have the right to opt out of the sale of your personal information.  You may exercise this right by clicking on the “Do Not Sell My Personal Information – U.S.” link located at the bottom of our homepage or by submitting a request as described in the “Submission of Requests” section below.  In addition, if you are a California resident, you have the right to opt out of the sharing of your personal information with any third party for the purpose of targeted advertising. You may exercise this right by clicking on the “Do Not Sell My Personal Information – U.S.” link located at the bottom of our homepage or by submitting a request as described in the “Submission of Requests” section below.

Right to Nondiscrimination.  We do not discriminate against California residents who exercise any of their rights described in our privacy policy.

Submission of Requests.  You may submit a request regarding your personal information by:

Calling us at 1-800-327-5256.

Emailing us at – please provide your name, telephone number, and type of request (that is, a request for categories of information, a request for specific pieces of information, a request to delete, or a request to opt out the sale of your information).

On My Privacy Options

What We May Need from You.  We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to someone who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Verifying Your Identity: To protect your privacy and security, we will take reasonable steps to verify your identity before providing your personal information and before deleting your information. Only you or someone legally authorized to act on your behalf may make a verifiable request related to your personal information. For example, if you make a request, we will ask you to confirm your name, email address, and/or other information we in our records to verify your identity, so that we can help protect your information.  

Requests from Authorized Agents:  You may designate an authorized agent to make a request for you.  If you designate an authorized agent to make a request on your behalf, we may require you to verify your identity and provide the authorized agent’s identity and contact information to us.

Responses to Requests.  We will confirm receipt of your request within 10 business days of receipt and generally will respond to your request within 45 days of receipt.  If we need more time to respond, we will inform you of the reason and we may take up to an additional 45 days to respond.  

No Fee Usually Required.  You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.  


If you have questions or concerns regarding this Privacy Policy, please contact us at the information provided below.

Betty Dain Creations, LLC 
9701 NW 112th Ave, Suite 10
Miami, FL 33178