Introduction

We ("we", "us", "our") take the protection of the data of users ("users" or "you") of our website and/or our mobile app (the "website" or the "mobile app") very seriously, and we are committed to protecting the information that users provide to us in connection with their use of our website and/or mobile app (together, the "digital assets"). We are further committed to protecting and using your data in accordance with applicable law.

This privacy policy explains our practices regarding the collection, use and disclosure of your data through your use of our digital assets (the "services") when you access the services from your devices.

Please read this privacy policy carefully and make sure you fully understand our practices regarding your data before you use our services. If you have read this policy, fully understand it and do not agree with our practices, you must stop using our digital assets and services. By using our services you accept the terms of this privacy policy. Your continued use of the services constitutes your agreement to this privacy policy and to any changes to it.

In this privacy policy you will learn:

How we collect data
What data we collect
Why we collect this data
Who we share the data with
How we use the "Lia" chatbot
Where the data is stored
How long the data is retained
How we protect the data
How we treat minors
Updates or changes to this privacy policy

What data do we collect?

Category: Always

Below is an overview of the data we may collect:

Unidentified and non-identifiable information that you provide during the registration process or that is collected through your use of our services ("non-personal data"). Non-personal data does not reveal who it was collected from. The non-personal data we collect consists mainly of technical and aggregated usage information.

Individually identifiable information, meaning any information by which you can be identified or could be identified with reasonable effort ("personal data"). The personal data we collect through our services may include information requested from time to time, such as names, email addresses, postal addresses, telephone numbers, IP addresses and more. Where we combine personal data with non-personal data, we treat the combined data as personal data for as long as it remains combined.

How do we collect data?

Category: Always

The main methods we use to collect data are set out below:

We collect data through your use of our services. When you visit our digital assets and use the services, we may collect, record and store information about your usage, sessions and related activity.

We collect data that you provide to us yourself, for example when you contact us directly through a communication channel (such as an email containing a comment or feedback).

We may collect data from third-party sources, as described below.

We collect data that you provide when you sign in to our services through a third party such as Facebook or Google.

Why do we collect this data?

Category: Always

We may use your data for the following purposes:

to provide and operate our services;
to develop, customise and improve our services;
to respond to your feedback, enquiries and requests and to provide assistance;
to analyse request and usage patterns;
for other internal, statistical and research purposes;
to strengthen our data security and fraud prevention capabilities;
to investigate violations, enforce our terms and policies, and comply with applicable law, regulations and official orders;
to send you updates, news, promotional material and other information relating to our services. For promotional emails, you can decide whether you wish to continue receiving them. If not, simply click the unsubscribe link in those emails.

Who do we share this data with?

Category: Always

We may share your data with our service providers in order to operate our services (for example, storing data with third-party hosting providers, providing technical support and so on).

We may also disclose your data in the following circumstances: (i) to investigate, detect, prevent or act against unlawful activity or other misconduct; (ii) to establish or exercise our rights of defence; (iii) to protect our rights, our property or our personal safety, as well as the safety of our users or the public; (iv) in the event of a change of control of our company or of one of our affiliates (by way of a merger, acquisition or purchase of substantially all assets, among others); (v) to collect, hold and/or manage your data through authorised third parties (such as cloud service providers) where this is reasonable for business purposes; (vi) to work with third parties on improving your user experience. For the avoidance of doubt, we may transfer, share or otherwise use non-personal data with third parties at our discretion.

Category: User has a blog or a forum

Please note that our services enable social interaction (such as posting content, information and comments publicly, and chatting with other users). Please be aware that any content or data you provide in these areas may be read, collected and used by other people. We advise against posting or sharing information that you do not wish to make public. If you upload content to our digital assets, or otherwise make it available in the course of using a service, you do so at your own risk. We cannot control the actions of other users or members of the public who have access to your data or content. You acknowledge and confirm that copies of your data may remain accessible on cached and archived pages even after deletion, or where third parties have copied or stored your content.

"Lia" chatbot

Category: Always

We use the AI-powered chatbot "Lia" on our website, which you can ask about our services, prices, opening hours and locations.

Data processed

When you use the chat, we process the content of your messages, the chatbot's replies, the language version of the website you are using, a randomly generated session identifier and the time of your enquiry. The session identifier is stored solely in your browser's memory and is deleted when you close the browser tab. Its only purpose is to technically group messages belonging to the same conversation, and it does not allow any conclusions to be drawn about your identity.

We do not ask you for personal data. However, because you write your messages freely, they may contain information relating to you, for example if you mention your name or your address. Please do not share health data or any other particularly sensitive information in the chat. Questions about allergies and intolerances are answered exclusively in person at the salon.

Recording of button clicks

Where the chatbot offers you a button to book an appointment or to open a location on a map, we record whether you clicked it. We store the time of the click, the type of button and its label, each alongside the message it belonged to. This allows us to see whether the chatbot is genuinely helping you, and to improve its answers.

We do not use cookies or third-party analytics services for this. The information is stored solely in our website's database and is not passed on to third parties. It does not allow any conclusions to be drawn about your identity. We have no visibility of what happens after the click on our booking provider's site; their own privacy policy applies there.

Use of an AI service

To generate the replies, we transmit your messages to the application programming interface of the Gemini service operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. This may involve a transfer to third countries outside the European Union, in particular to the USA. Google processes the data on our behalf. Further information can be found in Google's privacy policy at https://policies.google.com/privacy

Distance calculation

If you ask in the chat how far away one of our salons is, or how to get there, you may voluntarily provide an address. We transmit this address to the Routes API operated by Google Ireland Limited in order to calculate the driving distance and the estimated driving time to our locations. Providing an address is voluntary. Without an address, we will list our locations without any distance information.

Before we store the conversation, we automatically replace any address we detect with the placeholder "[customer address]". The address you provide is therefore not stored permanently.

Storage

We store the content of conversations in our website's database in order to evaluate and improve the chatbot and to identify recurring customer questions.

Rating the chat

At the end of a conversation you can voluntarily rate the chat and leave a comment. The rating and comment are sent to us by email and are used solely to improve our offering.

Legal basis

The legal basis for this processing is Article 6(1)(f) GDPR. Our legitimate interest lies in providing website visitors with fast and relevant advice and in improving our offering. You may object to this processing at any time under Article 21 GDPR. Use of the chatbot is voluntary. Alternatively, you can reach us by telephone or in person at one of our salons.

Hosting

Our website is operated by Wix.com Ltd. Chat histories are stored in our website's database. For details, please see the section on hosting in this privacy policy.

Cookies and similar technologies

When you visit or access our services, we authorise third parties to use web beacons, cookies, pixel tags, scripts and other technologies and analytics services ("tracking technologies"). These tracking technologies may allow third parties to automatically collect your data in order to improve the browsing experience on our digital assets, optimise their performance, provide a tailored user experience, and for security and fraud prevention purposes.

To find out more, please read our cookie policy.

Category: The user is NOT connected to an advertising service

We will not share your email address or other personal data with advertising companies or advertising networks without your consent.

Category: The user is connected to an advertising service, a campaign manager or Facebook Ads

We may deliver advertising through our services and our digital assets (including websites and applications that use our services), which may also be tailored to you, for example ads based on your recent browsing activity across websites, devices or browsers.

To deliver these ads to you, we may use cookies and/or JavaScript and/or web beacons (including clear GIFs) and/or HTML5 local storage and/or other technologies. We may also engage third parties, such as network advertisers (third parties that display ads based on your website visits), to serve targeted advertising. Third-party advertising network providers, advertisers, sponsors and/or website traffic measurement services may likewise use cookies and/or JavaScript and/or web beacons (including clear GIFs) and/or Flash cookies and/or other technologies to measure the effectiveness of their ads and to tailor advertising content to you. These third-party cookies and other technologies are governed by the respective third party's own privacy policy and not by this one.

Where do we store the data?

Category: Always

Non-personal data

Please note that our companies, as well as our trusted partners and service providers, are based around the world. For the purposes described in this privacy policy, we store and process all non-personal data that we collect in various jurisdictions.

Category: User collects personal data

Personal data

Personal data may be maintained, processed and stored in the United States, Ireland, South Korea, Taiwan, Israel and, where necessary for the proper provision of our services and/or required by law (as further explained below), in other jurisdictions.

How long is the data retained?

Category: Always

Please note that we retain the data we collect for as long as necessary to provide our services, to comply with our legal and contractual obligations towards you, to resolve disputes and to enforce our agreements.

We may correct, supplement or delete incomplete or inaccurate data at any time at our own discretion.

How do we protect the data?

Category: Always

The hosting service for our digital assets provides us with the online platform through which we can offer you our services. Your data may be stored through our hosting provider's data storage, databases and general applications. It stores your data on secure servers behind a firewall and provides secure HTTPS access to most areas of its services.

Category: User accepts payments / eCommerce

All payment methods offered by us and by our hosting provider for our digital assets comply with the PCI-DSS (Payment Card Industry Data Security Standard) of the PCI Security Standards Council, a joint effort of brands such as Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card data (including physical, electronic and procedural measures) by our shop and its service providers.

Category: Always

Notwithstanding the measures and efforts taken by us and by our hosting provider, we cannot and will not guarantee absolute protection or absolute security of the data you upload, publish or otherwise share with us or with others.

For this reason, we ask you to choose strong passwords and, wherever possible, not to share confidential information with us or with others where you believe its disclosure could cause you significant or lasting harm. As email and instant messaging are not considered secure forms of communication, we also ask you not to share confidential information through either of these channels.

How do we treat minors?

Category: User does NOT collect data from minors

The services are not intended for users who have not yet reached the age of majority. We will not knowingly collect data from children. If you have not yet reached the age of majority, you should not download or use the services and should not provide us with any information.

We reserve the right to request proof of age at any time so that we can verify whether minors are using our services. Should we become aware that a minor is using our services, we may deny and block that user's access to our services and may delete all data we hold about that user. If you have reason to believe that a minor has provided data to us, please contact us as explained below.

Category: User collects data from minors

Children may use our services. However, if they wish to access certain features, they may need to provide certain information. Some data (including data collected through cookies, web beacons and other similar technologies) may be collected automatically. Where we knowingly collect, use or disclose data collected from a child, we will provide notice and obtain parental consent in accordance with applicable law. We do not make a child's participation in an online activity conditional on the child providing more contact information than is reasonably necessary to take part in that activity. We use the data we collect only in connection with the services the child has requested.

We may also use a parent's contact details to communicate about the child's activities within the services. Parents may review the data we have collected from their child, prohibit us from collecting further data about their child, and request that all data we have collected be deleted from our records.

Please contact us to review, update or delete your child's data. To protect your child, we may ask you for proof of your identity. We may refuse you access to the data if we believe your identity is in question. Please note that certain data cannot be deleted due to other legal obligations.

Category: Always

We use your personal data only for the purposes set out in this privacy policy, and only where we are satisfied that:

the use of your personal data is necessary to perform or enter into a contract (for example, to provide you with the services themselves or with customer care or technical support);
the use of your personal data is necessary to comply with applicable legal or regulatory obligations; or
the use of your personal data is necessary to support our legitimate business interests (provided that this is always done in a manner that is proportionate and respects your privacy rights).

As an EU resident, you may:

request confirmation as to whether or not personal data concerning you is being processed, and request access to the personal data we hold about you as well as certain additional information;
request to receive the personal data you have provided to us in a structured, commonly used and machine-readable format;
request the rectification of the personal data we hold about you;
request the erasure of your personal data;
object to our processing of your personal data;
request the restriction of the processing of your personal data; or
lodge a complaint with a supervisory authority.

Please note, however, that these rights are not unconditional and may be subject to our own legitimate interests and to regulatory requirements. If you have general questions about the personal data we collect and how we use it, please contact us as set out below.

In the course of providing the services, we may transfer data across borders to affiliates or other third parties, and from your country or jurisdiction to other countries or jurisdictions worldwide. By using the services, you consent to the transfer of your data outside the EEA.

If you are resident in the EEA, your personal data will only be transferred to locations outside the EEA where we are satisfied that an adequate or comparable level of protection for personal data is in place. We will take appropriate steps to ensure that we have suitable contractual arrangements with our third parties, so that appropriate safeguards are in place, the risk of unlawful use, alteration, deletion, loss or theft of your personal data is minimised, and those third parties act in accordance with applicable law at all times.

Rights under the California Consumer Privacy Act

If you use the services as a California resident, you may have the right under the California Consumer Privacy Act ("CCPA") to request access to and deletion of your data.

To exercise your right of access and deletion, please see below for how to contact us.

Category: The website does not sell its users' data

We do not sell users' personal data for the intents and purposes of the CCPA.

Category: Websites with a blog or forum

Users of the services who are California residents and under 18 years of age may request and obtain removal of content they have posted, by emailing the address given in the "Contact" section below. All such requests must be labelled "California Removal Request". Every request must include a description of the content you wish to have removed, together with sufficient information to allow us to locate the material. We do not accept notices that are not labelled or not properly submitted, and we may be unable to respond if you do not provide sufficient information. Please note that your request does not ensure complete or comprehensive removal of the material. For example, material you have posted may be republished or reposted by other users or by third parties.

Updates or changes to this privacy policy

Category: Always

We may revise this privacy policy from time to time at our own discretion; the version published on the website is always the current one (see the "last updated" note). We ask you to review this privacy policy regularly for changes. Where changes are material, we will post a notice to that effect on our website. If you continue to use the services after being notified of changes on our website, this constitutes your acknowledgement of and agreement to the changes to the privacy policy and your consent to be bound by the terms of those changes.

Contact

Category: Always

If you have general questions about the services or about the data we collect about you and how we use it, please contact us at:

Name:
Address:
Email address:

DISCLAIMER

The information contained here is not a substitute for legal advice and you should not rely on it alone. Specific requirements regarding legal terms and policies may differ from state to state and/or from jurisdiction to jurisdiction. As set out in our terms of use, you are responsible for ensuring that your services are permitted under the law applicable to you and that you comply with it.

To make sure you fully meet your legal obligations, we strongly recommend that you seek professional advice so you can better understand which requirements apply to you specifically.