Privacy and Cookie Policy - Last updated July 2020

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy is maintained by FineLooks Technologies. This privacy and cookies policy ("Privacy Policy") details data used on www.finelooks.co.uk (the "Websites"), the FineLooks Customer mobile application software and the FineLooks Partner application software and website at finelooks.co.uk, both of which are available for download from App Store and Google Play (the "Apps"), customisable websites hosted on finelooks.co.uk, through which customers can make bookings directly with Partners at finelooks.co.uk. Fine Looks Technologies Limited is the data controller for your information - registered address: Kemp House 160 City Road, London EC1V 2NX) ("FineLooks", "we", "our" or "us"). Contact us on support@finelooks.co.uk. 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, 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.

We may collect the following information: We may share Your personal information with Service Providers to monitor and analyze the use of our Service,  to contact You. Affiliates include our company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us. With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions. With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile. Communication with us through the Platform, live chat, email, telephone, SMS, or social media) will be recorded for evidence for fact that you have contacted us, the content of your and our communication, your contact details, and other unique identifiers including IP address and display name.

To notify you about new FineLooks services and special offers we think you will find valuable, for example via email and displaying advertising on third party websites such as Facebook (where consent is required) To send you information about competitions and surveys and details of promotional offers of our Partners and other selected third parties’ goods or services, for example, those of health, beauty, leisure and lifestyle brands, by email and as push notifications via the App. To pass your personal information to our Partners and other selected third parties, for example, health, beauty, leisure and lifestyle brands, to enable them to send you information about their goods and services on their behalf. To place cookies and use similar technologies following the Cookies section of this Privacy Policy and the information provided to you when those technologies are used. To use customer communications for training, record-keeping and quality control purposes. If you telephone our customer experience team, and consent by not opting out, your call may be recorded. You will be told if such a recording is being made and allowed opt-out of being recorded if you wish to do so and the means for doing so. 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 Legitimate Interests Balancing Tests. We have carried out balancing tests for all the data processing we carry out based on our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us at support@finelooks.co.uk. 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 can 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 FineLooks sends you, you can do so by clicking the “unsubscribe” button at the bottom of email communications which we send you or by contacting us at support@finelooks.co.uk. 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. Please note that where you have opted out of receiving our email marketing communications via the methods described above, 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.

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 any of our Group Companies for the purposes identified in this Privacy Policy. A list of local Group Company entities and their locations is as follows:

  • Fine Looks Technologies Limited: Kemp House 160 City Road, London EC1V 2NX, support@finelooks.co.uk

• If you place an order or otherwise engage with FineLooks through a website or app powered on behalf of a third party, then your contact details and details of your order will be passed on to the relevant third party, for example when you make a booking via a third party If you give a third party the relevant consents (which FineLooks collects on behalf of third parties), they may also send you marketing communications.

• To third-party service providers that perform functions on our behalf concerning the Platform or otherwise in connection with the running of our business, recruiting candidates and for the provision of FineLooks' 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 including telephone calls and live chat).

• To our Partners with whom you book services whether via our Website or Apps, where we act as a commercial booking agent, or directly with the Partner via our Partner Platform, where we act solely as a technology provider. Your information is shared with Partners so that:

  • bookings can be facilitated and, if necessary, contact made in advance of your appointment;

  • if you have opted into 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 an individual level.

• To third party brands with which we collaborate on products, services, competitions and campaigns

• To third party salon software providers used by our Partners to ensure that those third-party software solutions and Connect each display real-time availability to customers

• To Media agencies and advertising partners to run targeted marketing campaigns (please see the Cookies section of this Privacy Policy for further information on online advertising practices)

• To other third parties, to facilitate our business and improve our products, content, services or advertising including, by way of example only, sending email communications or publishing reviews of our or our Partners' products and services

• 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 data to comply with any legal obligation or 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.

Please note by posting any Personal Information in any publicly accessible area of our Platform (such as review sections), such information may be collected by third parties over which we have no control. We are not responsible for the use of such information by such third parties.

Please, therefore, exercise all due care and consideration before disclosing any Personal Information that will be disclosed on public areas. You should also avoid disclosing on public areas any Personal Information that may be used to identify you (such as your name, age, home or work address or name of your employer).

Stripe

We use a third-party payment processor, Stripe, to process all payments made by you on our Website & App. FineLooks does not store credit card details and instead relies on Stripe for this. We obtain limited information from Stripe such as the last four digits, the country of issuance and the expiration date. The processing of such data by Stripe is covered by their privacy policy which may be viewed here: https://stripe.com/privacy

Stripe’s services in Europe are provided by a Stripe affiliate, Stripe Payments Europe Limited, an entity located in Ireland. In providing its payment processing services, Stripe Payments Europe Limited transfers personal data to Stripe, Inc. in the US. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of Stripe’s privacy policy entitled “International Data Transfers.

Your rights concerning your personal information

Concerning 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 requirements, 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 concerning 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 support@finelooks.co.uk. 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.

Social Media and User Generated Content

Some of our Platforms allow users to submit their content. Please remember that the public can view any content submitted to one of our platforms, and you should be cautious about providing certain personal information e.g. financial information or address details via these Platforms. We are not responsible for any actions taken by other individuals if you post personal information on one of our social media platforms, e.g. Facebook or Instagram. Please also refer to the respective privacy & cookie policies of the social media platforms you are using.

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 may be transferred to and stored at a destination outside the UK and European Economic Area (EEA), including in the US, including for the purposes of processing that data by selected third parties, to facilitate FineLooks' 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 personal data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification, a vendor's Processor Binding Corporate Rules, or another adequacy mechanism established under applicable data protection law. A copy of the relevant mechanism can be provided for your review on request to support@finelooks.co.uk.

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. For example:

• where you apply for a position at Fine Looks, whether directly or indirectly, information which you provide will be held for 12 months and may be referred to should you make future applications to work at Fine Looks, unless you opt to delete this data which you may do so by following the link in the confirmation of application email that we sent you;

• where you contact us via live chat on the Platform, we usually retain customer live chat data for up to 60 days after the end of the session; and

• where you contact us via telephone and do not opt-out, we shall retain call recordings for up 90 days from the date of the call.

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) to enhance your user experience, improve our site and provide tailored offers on Fine Looks and other sites.

Please see the table below for a live breakdown of the Cookies that are used on our Platform:

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off – our Platform cannot function properly without them. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. 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 do not store any personally identifiable information.

Performance Cookies

These cookies enable us to better understand how many users visit our Platform, how users arrive at, browse or use our Platform and which parts of our Platform are most popular. For example, they allow us to count visits and traffic sources so we can measure and improve the performance of our site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.

Functional Cookies

These cookies enable us to provide enhanced functionality and personalisation and simplify your user experience. For example, they may remember choices you make such as the country you visit our Platform from or your preferred language. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly. They cannot track your browsing activity on other websites or apps outside the Platform.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.