Introduction

This privacy and cookies policy (“Privacy Policy”) details data used on onlinebooking.totalsalon.net (the “Website”), the Customer mobile application software, and on our salon partners (“Partners”)’ booking system SalonControl (together, the “Platform”).

The data processor for your information on behalf of Pure Hair is Total SalonControls Ltd (registered address: Tallford House, 38 Walliscote Road, Weston-Super-Mare, North Somerset, England, BS23 1LP). The data controller for your information is Pure Hair (registered address: 17 Henley Crescent, Solihull, Solihull, B91 2JD) (“SalonControl”, “Pure Hair“, “we”, “our” or “us”).

We are committed to protecting the privacy of our users and customers. This Privacy Policy is intended to inform you how we gather, define, and use information that could identify you, such as your name, mobile phone number, email address, address, other contact details or online identifiers, other information that you provide to us when using the Platform (“Personal Information”) and also what Cookies we use. Please take a moment to read this Privacy Policy carefully.

What information do we collect?

When you visit and/or use our Platform or contact us, we may collect the following information:

• Personal Information that you choose to share with us when you register for an account, subscribe to emails, newsletters and alerts and which you provide to us when using our services, including information entered into our booking platform and included in your comments. In the course of making a booking, you might voluntarily provide us with sensitive personal data if relevant to the service that you are requesting or reviewing (relating to your health or ethnicity, for example).
• If you choose to communicate with us (for example, through the Platform, email, telephone, SMS, or social media) we will record the fact that you have contacted us and may retain the content of your communication, together with your contact details and our responses.

Information about your visits to and use of the Platform, such as information about the device and browser you are using, your IP address and location, your identifier for advertisers (IDFA), the date and time that you visited, the duration of your visit, the referral source and website navigation paths of your visit and your interactions on the Platform including the salons and treatments you are interested in. Please note that we may associate this information with your account. Please see the cookies section of this Privacy Policy for further information on the purposes for which we collect and use this information. It is important that all the Personal Information you give us when you register as a user or otherwise when you use the Platform is correct and accurate. This includes, by way of example only, ensuring that we have your correct contact (including mobile number) details at all times.

If you plan to submit someone else’s Personal Information to us, for instance when making a booking on their behalf, you should only provide us with that third party’s details with their consent and after they have been given access to information about how we will use their details, including the purposes set out in this Privacy Policy.

Protecting your personal information

The transmission of information via the internet is not completely secure. So, whilst we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our Platform. Any transmission is at your own risk. Once we have received your Personal Information we will use strict procedures and security features in relation to that data.

How do we use your personal information?

In general terms, we use Personal Information to provide you with the services and products you request, provide customer services, deliver our content and ads which we think may be of interest to you, for customer research, to send you marketing and promotional emails/sms’ and to notify you about important changes to our Platform.

We also use your Personal Information for the following purposes:

• To fulfil a contract, or take steps linked to a contract. This is relevant where you request a service via Pure Hair & Total SalonControl Ltd. This includes:
  • Sending you information about your requested services (such as appointment reminders) by email, SMS and push notification
  • Facilitating your bookings
  • Responding to your questions and concerns
  • Administering your account
• As required by Pure Hair & Total SalonControl Ltd to conduct our business and pursue our legitimate interests, in particular:
  • To keep our Platform and systems secure and to prevent fraud, security incidents and other crime
  • To verify compliance with our terms and conditions and for the establishment, exercise or defence of legal claims
  • To notify you about new Pure Hair services and special offers we think you will find valuable, for example via sms
  • To tailor and personalise marketing notifications and advertising for you based on information you provide and your use of our Platform, products and services
  • To help us monitor, improve and protect our Platform, products and services, and to personalise our Platform, products, services for you, based on information you provide and your use of our Platform, products and services
  • To investigate and respond to any questions or complaints received from you or from others, about our Platform or our products or services
  • To conduct internal research and analysis so that we can see how our Platform, products and services are being used and how our business is performing
  • To use customer communications for training, record-keeping and quality control purposes. If you telephone our customer experience team, please note that the fact that you have contacted us will be noted and your call may be recorded. You will be told if such a recording is being made and also given the opportunity to opt-out of being recorded if you wish to do so and the means for doing so
• Where you give us consent:
  • To notify you about new Pure Hair services and special offers we think you will find valuable, for example via sms
  • To place cookies and use similar technologies in accordance with the Cookies section of this Privacy Policy and the information provided to you when those technologies are used
  • on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time
• For purposes which are required by law:
  • To respond to requests by government or law enforcement authorities conducting an investigation
  • To meet legal, regulatory and compliance requirements

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

• If you would like to unsubscribe from receiving communications which Pure Hair sends you, you can do so by clicking the “unsubscribe” button at the bottom of email communications which we send you or alternatively by contacting us at info@purehairsolihull.co.uk or 01217056767. In the case of email marketing please allow 48 business hours for your email address to be removed from our system.
• If you would like to unsubscribe from receiving communications which are sent by Partners and other third parties, please contact the Partner or third party directly. In the case of our Partners, if you need our assistance with this, we will be happy to do what we can to help you.
• If you would like to no longer receive push notifications via the App, you can do so by revoking push notification permission for the Apps in your phone’s operating system settings.

Sharing personal information with third parties

We treat the security and method of processing your Personal Information very seriously, and we will never sell your Personal Information under any circumstances. However, we may disclose your Personal Information to selected third parties, including in the following situations:

• To third party service providers that perform functions on our behalf in relation to the Platform or otherwise in connection with the provision of Pure Hair & Total SalonControl Ltd‘s services (for example, processing credit card payments, website hosting, conducting surveys and market research, providing social media analysis, providing marketing email services, data analysis tools and to manage customer services communications).
• To our Partners with whom you book services whether via our Website or Apps, where we act as commercial booking agent, or directly with the Partner via our Partner Platform or Widgets, where we act solely as a technology provider. Your information is shared with Partners in order that:
• • bookings can be facilitated and, if necessary, contact made in advance of your appointment;
  • if you have opted in to receiving marketing emails from Partners with which you book, these emails can be sent to you containing news and special offers; and
  • they can improve the services they offer to their customers and business operations by providing statistical data regarding customers, both on an aggregated basis and on an individual level.
• If we buy, sell or transfer any business or assets or if go into insolvency, bankruptcy or receivership. If this should happen, we may need to disclose your Personal Information to the seller or buyer of such business or assets, as appropriate
• If we are under a duty to disclose or share your Personal Data to comply with any legal obligation or in order to enforce or apply our terms and conditions and other agreements or protect the rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction
• To government authorities, and to other third parties as required or permitted by law, including but not limited to in response to court orders. We also may disclose user information when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of our Platform, or anyone else that could be harmed by such activities.

Your rights in relation to your personal information

In relation to the personal information we hold about you, you may be entitled to ask us:

• For a copy of your personal information
• To correct, erase or restrict the processing of your personal information
• To obtain personal data which you provide to us for a contract or with your consent in a structured, machine readable format and to ask us to transfer this information to another organisation To object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

In the first instance you may be able to view or change the information you have provided us with by logging in to your online account.

Your rights in relation to your personal information are limited in some situations. For example, if fulfilling your request would reveal personal data about another person or if we have a legal requirement or a compelling legitimate ground we may continue to process Personal Information which you have asked us to delete. You also may have the right to make a complaint if you feel your personal information has been mishandled. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant supervisory authority.

If you wish to exercise any of the above rights, please contact us at info@purehairsolihull.co.uk, 01217056767 or info@totalsalon.net. Please note, however, that no financial information will be provided without verification.

What about other websites linked to our Platform?

We are not responsible for the practices employed by websites linked to or from our Platform nor the information or content contained therein. Often links to other websites are provided solely as pointers to information on topics that may be useful to the users of our Platform.

Please remember that when you use a link to go from our Platform to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including websites which have a link on our Platform, is subject to that website’s own rules and policies. Always read over those rules and policies before proceeding.

Changes to our Privacy Policy

If we change our privacy policies and procedures, we will post those changes on our Platform to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it.

Where we store your personal data

The data that we collect from you is generally stored at premise of Pure Hair. However, for the purposes of data backup your data may be transferred to and stored at a destination outside the European Economic Area (EEA), including for the purposes of processing that data by selected third parties, in order to facilitate our business. Countries outside the EEA may not have laws which provide the same level of protection to your personal data as laws within the EEA. Where this is the case we will put in place appropriate safeguards to ensure that such transfers comply with applicable data protection laws.

Retention

We retain your Personal Information for as long as is required to fulfil the activities set out in this Privacy Policy, otherwise communicated to you or for as long as is permitted by applicable law.

Our policy on Cookies

In common with other commercial websites and apps, our Platform use standard technologies including cookies and similar tools including web server logs, web beacons, tokens, pixel tags, local storage, device identifiers and tracking IDs (together referred to as “Cookies” in this Privacy Policy) for the purposes set out below.

Note that third parties collect and use data from Cookies placed on the Platform. This Privacy Policy may not describe the privacy practices of such third parties. We encourage you to read the privacy policies of these third parties and, if you prefer to not have data reported by these parties, follow their opt-out processes where these exist. Please review “What can I do to change my Cookies preferences?” section below for further information.

Why do we use Cookies?

Strictly Necessary/Transactional Purposes

Using Cookies for this purpose is essential for our Platform to work correctly. They may be required to enable you to move around our Platform and use our features, for system administration, to prevent fraudulent activity, to keep you logged in from one page to another or so that we can remember what you have added to your basket. These cookies cannot be switched off as our Platform cannot function properly without them.

Functionality Purposes

Using Cookies for this purpose enables us to enhance and simplify your user experience. For example they may remember choices you make such as the country you visit our Platform from, language, search parameters such as date, area or treatment, and help to identify issues with our Platform (such as crash incidents). These can then be used to provide you with an experience more appropriate to your selections and to tailor and enhance your visits to our Platform. The information these technologies collect may be personally identifiable, such as your log-in details. They cannot track your browsing activity on other websites or apps outside the Platform. We use some tools for this purpose, for example Snowplow.

Performance Purposes

Using Cookies for this purpose enables us to better understand how many users visit our Platform, how users arrive at, and browse or use our Platform and which parts of our Platform are most popular. This helps us to improve the Platform, such as navigation and interface experience, and improve our products and services. To achieve this, we collect information on how people use our Platform and use third party technologies for this purpose, including but not limited to Google Analytics, Snowplow, Optimizely, Hotjar, AppsFlyer, Fabric Analytics, Firebase, and Crashlytics. We also use these Cookies to help us measure the effectiveness of our online marketing and advertising activities. We use some third party Cookies for this purpose, including but not limited to Salesforce Marketing Cloud, Snowplow, Impact Radius, Awin, DoubleClick Floodlight, Bing, and tools provided by social media platforms (including Facebook and Snapchat).

These technologies remember the sites you visit and that information is shared with other parties such as advertisers. When we use third parties for advertising and targeting purposes, we may disclose:

• Personally identifiable information, such as email address, order ID, venue.
• Generic, aggregated or anonymised data relating to your visits and use of our Platform; or
• Information in a pseudonymised form such as a browser cookie ID / code or cryptographic hash of your email address to help us tailor and display our ads to you on other services. This ID or code is matched against your equivalent unique code similarly generated by our ad partners to tailor adverts to you. The third party companies that we use for targeting and advertising purposes have their own privacy policies which you should read in detail.

How do we use information we collect from tracking technologies?

See “How do we use your personal information?” above.

What can I do to change my Cookies preferences?

• Please find below a number of ways in which you can manage your Cookie preferences online. Please also refer to the privacy & cookie policies of the relevant third party for more information.
• Most browsers and devices allow you to remove tracking technologies and/or block new tracking technologies being set. To turn off tracking technologies, look at the “help” menu on your browser, or visit your device settings. However, please note, that (a) this may not be effective for all tracking technologies and (b) switching off tracking technologies may restrict your use of the Sites and/or delay or affect the way in which they operate.
• Use your mobile device settings to configure your advertising preferences.
• Google Analytics: If you prefer to not have data reported by Google Analytics, you can install the Google Analytics Opt-Out Browser Add-On by following the instructions here: tools.google.com/dlpage/gaoptout. You may opt out of Google’s use of Cookies by visiting the Google advertising opt-out page here www.google.com/policies/technologies/ads/.
• Please note that where you have opted out of receiving our email marketing communications via the methods described above under the section “Withdrawing consent or otherwise objecting to direct marketing”, you may still see our non-targeted adverts whilst you are online, if your interests settings on Facebook are aligned to an audience segment (pre-defined by Facebook) which our business is also associated with. We do not control whether these ads are displayed to you.
• In the case of third parties not specified in this section, please consult their relevant privacy & cookies policy to find out more about adverts displayed to you whilst you are online and how you can opt-out.

Conditions of using our website

• A wide range of intellectual property rights are used in and relating to this website, including:
  1. our the trade marks and logos;
  2. the design, text, graphics and other content of the web pages on this website, together with all the web addresses associated with those web pages; and
  3. all the software used in relation to this website.
• This website promotes the business referred to on it. In these conditions, the business will be referred to as ‘we’ and/or ’our’.
• We are the owner or the authorised licensee of these intellectual property rights. You agree not to copy any content (including images) on this website without our consent.

About these conditions

• If you access or use any part of this website you agree to these conditions. If you do not want to agree to these conditions, do not access or use this website.
• We may change these conditions at any time without giving you notice. Please check these conditions from time to time for any changes. By continuing to use the website you agree to all the changes we make to these conditions.

Using this website

• We collect and use information in line with our Privacy Policy . By using this website, you agree to the way in which we collect and use your information.
• You cannot use this website:
• for any unlawful purpose;
• to harm, threaten, abuse or harass another person, or in a way that invades someone’s privacy or is (in our reasonable opinion) offensive or is unacceptable or damaging to us, our customers or suppliers
• to create, check, confirm, update or amend your own or someone else’s databases, records, directories, customer lists, mailing or prospecting lists;
• to tamper with, update or change any part of the website
• in a way that affects how it is run;
• in a way that imposes an unreasonable or disproportionally large burden on us or our suppliers’ communications and technical systems as determined by us; or
• using any automated means to monitor or copy the website or its content, or to interfere with or attempt to interfere with how the website works.

If you provide content for this website

• If you provide any material to this website (for example, by providing ratings and reviews, comments, articles, or uploading any other content in any format (including video)) (each “User Content”). You agree to grant us permission, irrevocably and free of charge, to use User Content (including altering and adapting it for operational or editorial reasons) in any media worldwide, for our own marketing, research and promotional activities and our internal business purposes which may include providing the User Content to selected third party partners, service providers, social media and networking sites.
• You own your User Content at all times, and you continue to have the right to use it in any way you choose.

By providing any User Content to the Website you confirm that your User Content:

• is your own original work or you are authorized to provide it to the Website and that you have the right to give us permission to use it for the purposes set out in these terms;
• will not contain or promote anything illegal, harmful, misleading, abusive, defamatory (that is, it does not damage someone’s good reputation) or anything else that might cause widespread offence or bring us or our business partners into disrepute;
• does not take away or affect any other person’s privacy rights, contract rights or any other rights;
• does not contain any virus or other code that may damage, interfere with or otherwise adversely affect the operation of the Website;
• will, if used to promote your own business or services, clearly and openly state your association with the particular business expressly;
• will not contain any form of mass-mailing or spam.
• If you do not want to grant us the permissions set out above, please do not provide any material to the Website
• We have no obligation to publish your User Content on the Website and we retain the right to remove any User Content at any time and for any reason.
• We do not edit, pre-vet or review any User Content displayed on the Website. If you believe that any User Content does not comply with the requirements set out in this paragraph, please notify us immediately. We will then review the User Content and, where we deem it appropriate, remove it within a reasonable time.

Disclaimers

As far as the relevant laws allow, we do not guarantee that:

• You should not rely on the website for advice.
• You use the website at your own risk.
• there will be no problems with how you use the website; or
• the computer or server you use to log on to the website is free of viruses or other harmful programs.

Limits to our liability

There is no limit to what we and the people who provide our services will be liable for if someone dies or is injured because of our negligence or because we have committed fraud.

Under no circumstances will we, the owner or operator of this website, or any of their group companies, employees, officers or agents, or any other organisation involved in creating, producing, maintaining or distributing the website be liable for any loss of:

• profits;
• business or business opportunities;
• savings you expect to make;
• goodwill;
• use of, or corruption to information; or
• information.

If we do not keep to these conditions, they will only be liable for losses you have suffered as a direct result. We are not liable to you for any other losses whether such losses are because we have not kept to our obligations or contract, because of something we have done or not done in negligence, due to defamatory statements or liability for a product or otherwise as a result of:

• using or relying on the website;
• not being able to use the website;
• any mistake, fault, failure to do something, missing information, or virus on the website or if it does not work properly because of incidents outside of our control such as (but not limited to) interruptions to communication and networks and circumstances beyond our control;
• theft, destruction of information or someone getting access to our records, programs or services without our permission;
• goods, products, services or information received through or advertised on any website which we link to from this website; or
• any information, data, message or other material which you email, post, upload, reproduce, send, or otherwise distribute or receive using the website.

The whole agreement

• These conditions make up the whole agreement between you and us in how you use the website. If a court decides that a condition is not valid, the rest of the conditions will still apply.

The law

• The laws of England and Wales apply to your use of the website and these conditions. We control the website from within the United Kingdom. However, you can get access to the website from other places around the world. Although, these places may have different laws from the laws of England and Wales, by using the website you agree that the laws of England and Wales will apply to everything relating to you using the website and you agree to keep to these laws. We have the right to take you to court in the country you live in.