Privacy Policy

Secret Spa (London) Ltd, trading as Solo, is a private company limited by shares incorporated and registered in England and Wales with company number 09470015 whose registered office address is at 1-3 Brixton Rd, London, SW9 6DE, UK (“Solo”, “we”, “our”, or “us”).

Solo respects your privacy and is committed to protecting your personal data. This privacy notice (the “Policy”) will inform you as to how we look after your personal data when you (i) visit our website (regardless of where you visit it from), (ii) use our mobile application software (together, the website and mobile application software shall be the “Platform”) or (iii) interact with us on social media, as either a customer user (“Client”) or a beauty or wellness therapist user (“Therapist”) or a brand user (“Brand”) (listing Therapists and/or beauty or wellness therapists who have not signed up to use Solo (“Non-User Therapist”) on your marketplace) (together, the “user” or “you”), and tells you about your privacy rights and how the law protects you and your personal data.

This Policy is provided in a layered format so you can scroll down to the specific areas set out below. Please also use the glossary below to understand the meaning of some of the terms used in this Policy.

IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
LOCATION SERVICES/DATA
HOW YOUR PERSONAL DATA IS COLLECTED
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
GLOSSARY
COOKIE POLICY

1. Important information and who we are

Purpose of this privacy notice

This Policy aims to give you information on how Solo collects and processes your information through your use of the Platform, including any data you may provide when you request, purchase or perform a treatment, register and use our Platform, create a marketplace on our Platform (or are listed on a marketplace on our Platform), sign up to our newsletter or email subscription, register to attend one of our events, interact with us on social media, take part in a competition or survey, or interact with us in any similar way.

It also explains your rights in relation to your information and how to contact us or the relevant regulator in the event that you have a complaint. Our collection, storage, use and sharing of your information is regulated by law, including under the United Kingdom General Data Protection Regulations.

The Platform is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.

If you are a Therapist, we will also provide you with our staff and contractor privacy notice as you may on occasion, act as our contractor for B2B events separate to the Platform or there may be other occasions such as in respect of legal or tax processes in which we may need to process other types of data about you than is set out in this Policy.

Controller and Processor

If you are a Client, Therapist or Brand uploading your personal data to Solo, Solo is the controller and is responsible for your personal data.

If you are a Brand and you choose to upload a Non-User Therapist’s personal data to Solo, you are the controller responsible for their personal data up to the point that Solo becomes the controller. For this reason, prior to uploading a Non-User Therapist’s personal data to the Platform, we require that you provide a privacy notice to each Non-User Therapist confirming the personal data that you may upload to the Platform and the legal basis for doing so.

We are a Processor in respect of any personal data processed by Solo on behalf of any users. We only process your personal information where we are permitted to do so by law, meaning when we have one or more legal basis to do so. Paragraph 5 of this Policy explains how we process your personal information depending on the context of how personal information typically comes into our case and includes further information about the legal basis or bases that we rely on in those circumstances.

In certain circumstances, we rely on the legal ground known as ‘legitimate interests’ to process your personal information. This is where the processing of your personal information is necessary to pursue our legitimate interests in a way which is reasonably expected as part of running our business, but which is not detrimental to you and would have minimal impact on your privacy. We undertake an assessment of any potential impact on your privacy before we process your personal information for our legitimate interests.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Further Processing

Insofar as we wish to use your personal information for purposes other than those contained in this Policy, we will check whether these additional purposes are compatible with the original purposes. Depending on the circumstances, we will inform you about the change of purpose and the legal basis for using your personal information.

Contact details

Our full details are:

Full name of legal entity: Secret Spa (London) Limited, Company registration number: 09470015

Name or title of DPO: Head of People & Culture

Email address: data@secretspa.co.uk

Postal address: 1-3 Brixton Rd, London, SW9 6DE, UK.

Telephone number: 0207 096 0506

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (the “ICO”), the United Kingdoms’ supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to the Policy and your duty to inform us of changes

This version was last updated on 11 Dec 2023.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Platform, we encourage you to read the privacy notice of every website you visit or app you use.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (“Anonymous Data”).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

“Identity Data” includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
“Special Category Personal Data” includes details about your health (or race or religion if ever relevant to treatments requested or performed by you).
“Contact Data” includes billing address, residential address, business address, address at which you want the treatment to take place, email address and telephone number(s).
“Financial Data” includes bank account (or similar, such as PayPal account, as might be relevant from time to time) and payment card details.
“Transaction Data” includes details about payments to and from you as either a Client orTherapist or Brand, and as a Client other details of services or products you have purchased from us or from Therapists or through Brands.
“Technical Data” includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Platform.
“Profile Data” includes your username and password to use the Platform, purchases or orders made by you or fulfilled by you, your interests, preferences, social media interaction, feedback and survey responses.
“Usage Data” includes information about how you use the Platform and our services, as Clients, about your bookings, average order value, how you rate Therapists, retention and Platform visits, and, as Therapists, about how you perform services for Clients through the Platform, your bookings, average order value, how you are rated by Clients, retention and Platform visits, and as Brands, about Clients/Therapists making bookings through your marketplace.
“Marketing and Communications Data” includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us (such as withdrawing your registration as a Client, Therapist, or Brand, although that should only be in rare cases), but we will notify you if this is the case at the time.

3. Location Services/Data

The Platform will request your consent to use location services to precisely identify your location each session (unless you consent to the use of location services at all times the Platform is downloaded or open on your devices). We require access to Location Data (defined below) in order to identify local Therapists and Clients. If you do not provide your consent, you may not use the Platform.

If you are a Brand, a Therapist must have consented to use location services if their Location Data is intended to be listed on your marketplace. Similarly, you must obtain the consent of Non-User Therapists (or confirm another legal basis you are relying on) before uploading any information relating to their location on your marketplace. If you do not obtain the consent of a Non-User Therapist, or confirm another legal basis you are relying on, you may not use the Platform to upload any information relating to that Non-User Therapist’s location.

To withdraw your consent at any time, or if you are a Brand and a Non-User Therapist withdraws their consent, please contact us and (if applicable) disable the Location Data/services on your device (that will not affect the lawfulness of our use of that data in reliance on the consent before it was withdrawn).

We will not process your Location Data other than as strictly required.

The location services in the Platform will not operate unless Location Data/services are generally enabled on your device. You may disable such functionality at any time by disabling the location services on your device. When you allow your device to use Location Data/services, data will also be collected by the organisation providing the device operating system in accordance with their own privacy policies.

4. How your personal data is collected

We use different methods to collect data from and about you, including through:

Direct interactions. You may give us your (or, in the case of a Brand, your and certain Non-UserTherapists) Identity, Special Category, Contact, Financial, Profile, and Marketing and Communications Data by filling in details and forms on the Platform or by corresponding with us by post, phone, email, through our social media channels or otherwise. This includes, for example, personal data you provide to us when you:

create a marketplace on the Platform;
make or accept an appointment;
purchase or sign up to our services;
complete our pre-treatment questionnaires;
register to attend an event;
subscribe to our publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us some feedback directly through the Platform or through our Therapists.

Automated technologies or interactions. As you interact with our Platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Location Data. You may give us your Location Data (or any similar information relating to your location) by filling in forms or by corresponding with us by post, phone, email or otherwise. We also use GPS technology to determine your current location and match you with local Clients/Therapists. Some of our location-enabled services require your information for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling location services in your settings or by contacting us.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

“Technical Data” from analytics providers such as Google and Facebook, based outside theEuropean Union;
“Identity”, “Technical”, “Profile”, “Usage”, “Marketing and Communications”, “Contact”,“Financial” and “Transaction” Data from providers of technical, payment and delivery services, such as Solo’s external third parties, including but not limited to:
Stripe, Inc. is a global company we use to process online payments to Therapists and so that we can receive our commission. Their privacy policy can be accessed here https://stripe.com/gb/privacy
Mixpanel Inc is a global company which we use to process bookings between Clients andTherapists through the Platform. Their privacy policy can be accessed here https://mixpanel.com/legal/privacy-policy/
Mailchimp is a global company which we use for email marketing. Their privacy policy can be accessed here: https://mailchimp.com/legal/privacy/
Customer.io is a global company which we use for email marketing. Their privacy policy can be accessed here: https://customer.io/legal/privacy-policy/
Mention Me is a global company which we use for our refer-a-friend programme and related services. Their privacy policy can be accessed here: https://mention-me.com/help/privacy_policy
Rakuten Advertising is a global company we advertise with. Their privacy policy can be accessed here https://go.rakutenadvertising.com/hubfs/Services-Privacy-Policy-English.pdf
Hubspot is a global company which we use for CRM. Their privacy policy can be accessed here https://legal.hubspot.com/privacy-policy
Chargebee is a global company which we use for our subscription billing and revenue management. Their privacy policy can be accessed here https://www.chargebee.com/privacy/
Intercom is a global company which we use for customer support. Their privacy policy can be accessed here https://www.intercom.com/legal/privacy
Segment is a global company which we use as a data warehouse. https://www.twilio.com/en-us/legal/privacy
“Identity” and “Contact” Data from data brokers or aggregators such as Facebook, Instagram and Gmail; and
“Identity” and “Contact” Data from publicly availably sources such as Companies House and the Electoral Register or Therapist’s business websites based inside the European Union.

5. How we use your personal data

Under data protection law, we will only use your personal data if we have a proper reason for doing so. Most commonly, we will use your personal data where one or more of the following apply:

You have given consent.
We need to perform the contract we are about to enter into or have entered into with you.
It is necessary for our legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

See below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data if we are able to rely on another legal ground for processing your personal data, other than in relation to sending third party direct marketing communications to you via email or SMS text message and receiving your Location Data.

You have the right to withdraw consent to marketing and providing your Location Data at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

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Purpose/Activity

Type of data

Lawful Basis for processing including basis of legitimate interest

To register you as a new user of the Platform and/or allow you to create a marketplace on the Platform.

(a) Identity
(b) Contact
(c) Special Category
(d) Financial
(e) Profile
(f) Marketing and Communications
(g) Technical
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(a) Performance of a contract with you.

To process or deliver our services or your order to you, including:
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• allocating the correct Therapists to provide treatments to Clients and introducing Clients to Therapists;
• providing your location information or any other information obtained whilst using GPS technology and providing such information to Therapists or Clients or Brands;
• allowing Therapists to attend Clients’ premises;
• allowing Therapists to determine the best way to provide treatments to Clients or which products are most suitable;
• allowing Brands to create marketplaces to list Therapists and Non-User Therapists who offer their products or services;
• manage payments, fees and charges; and
• collect and recover money owed to us/or our Therapists and/or Clients (such as for a refund) and/or Brands.
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(a) Identity
(b) Contact
(c) Special Category
(d) Transaction
(e) Marketing and Communications
(f) Usage
(g) Financial
(h) Profile
(i) Technical
(j) Location

(a) Performance of a contract with you.
(b) Necessary for our legitimate interests (to recover debts due to us or for addressing safety issues for users).
(c) Consent.

To provide you with our analysis relating to your KPIs (if you are a Brand, your Therapists’ and Non-User Therapists’ KPIs) which will include (to the extent possible):
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• number and category of bookings;
• average order value of each booking;
• ratings and reviews of appointments;
• website visits; and
• retention rates.
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(a) Identity
(b) Usage
(c) Profile
(d) Transaction

(a) Performance of a contract with you.
(b) Necessary for our legitimate interests (to analyse Therapist and Brand success rates of products and services offered on the Platform, in order to develop and grow our business).

To manage our relationship with you, which will include:

• notifying you about changes to our terms or Policy; and
• asking you to leave a review or take a survey.

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(e) Usage

(a) Performance of a contract with you.
(b) Necessary to comply with a legal obligation.
(c) Necessary for our legitimate interests (to keep our records updated and to study how our users use our products/services).
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To enable you to partake in a promotion, prize draw, competition or complete a survey.

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Transaction
(g) Financial
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(a) Performance of a contract with you.
(b) Necessary for our legitimate interests (to study how users use our products/services, to develop them and grow our business).

To administer and protect our business and our Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
(b) Necessary to comply with a legal obligation.
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To deliver relevant Platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
(g) Transaction
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(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).

To use data analytics to improve our Platform, services, marketing, customer relationships and experiences.

(a) Technical
(b) Usage
(c) Profile
(d) Transaction
(e) Marketing and Communications

(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Platform updated and relevant, to develop our business and to inform our marketing strategy).
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To make suggestions and recommendations to you about services that may be of interest to you.

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Transaction
(g) Marketing and Communications
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(a) Necessary for our legitimate interests (to develop our products/services and grow our business).

All of the personal data we collect and use from you is stored and analysed for the above purposes only.

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Marketing

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We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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Promotional offers from us

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We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

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You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

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Third-party marketing

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We will get your express opt-in consent before we share your personal data with any third-party company for marketing purposes. If we do ask for your consent, it will only be in relation to carefully selected third-parties who we think may be of interest to you due to their close connection with the beauty industry.

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Opting out

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You can ask us or third parties to stop sending you marketing messages at any time by following the opt- out links on any marketing message sent to you or by contacting us at any time.

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Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transaction.

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Cookies

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You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy at the bottom of this page.

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Change of purpose

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We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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6. Disclosures of your personal data

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We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.

Brands, if you have consented to being listed on a Brand’s marketplace as a Therapist or Non-User Therapist offering its products/services.
External Third Parties as set out in the glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

We only allow Brands to receive your personal data (including relating to your KPIs) if we are satisfied that they have obtained your consent to being listed on their marketplace on the Platform, and that they take appropriate measures to protect your personal information.

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We only allow External Third Parties to handle your information if we are satisfied that they take appropriate measures to protect your personal information.

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Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

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We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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We or the External Third Parties occasionally also need to share your information with certain recipients who will be bound by confidentiality obligations as follows:

our or their external auditors;
our or their professional advisors (such as lawyers and other advisors);
law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and
regulatory obligations; and
other parties that have or may acquire control or ownership of our business (and our or their professional advisors) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. Usually such information will be anonymised, but this may not always be possible.

Personal data that you provide to those parties listed above or other third parties may be sent to us so that we can deliver our products and services effectively. Your personal data may also be accessed by third-party applications, such as gadgets or extensions. Any personal data, when you enable such a third-party application, is processed under the Policy. Any information collected by a third-party application provider is governed by their privacy policies.

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We may disclose your personal data with our social media network providers and any comments, statuses, updates, likes, tweets, etc. that you voluntarily share with us through our social media networks may appear on our Platform or social media channels in the designated areas that show activity on our Platform, social media pages or profiles.

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We may also share your non-personal, aggregated information with the parties listed above.

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7. International transfers

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Many of our external third parties are based outside the European Economic Area (the “EEA”) so their processing of your personal data will involve a transfer of data outside the United Kingdom/EEA.

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Whenever we transfer your personal data out of the United Kingdom/EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based elsewhere, for example in the USA, we may transfer data to them if they have signed up to standard contractual clauses and the international data transfer addendum.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the United Kingdom/EEA.

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8. Data security

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We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

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All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password than enables you to access the Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

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We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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If you want detailed guidance from Get Safe Online on how to protect your information and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

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9. Data retention

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How long will you use my personal data for?

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We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

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By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

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We reserve the right to make adjustments to the above periods that may result as a result of any orders, laws, or regulations issued by any governmental, legislative, or regulatory body with jurisdiction over us.

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In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you

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In the event you do not use the Platform for a period of ninety days, then we will treat the account as expired and your personal data may be deleted.

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10. Your legal rights

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You have a right at any time to request any of the following:

View or access the personal data we have collected about you, if any.
Change or correct any personal data we have collected about you.
Request us to delete any personal data we have collected about you.
Express any concern you have about our use of your personal data.

Under certain circumstances, you have rights under data protection laws in relation to your personal data to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on our legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note, this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.

If you wish to exercise any of the rights set out above, please contact us.

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No fee usually required

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You will not have to pay a fee to access your personal data (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.

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What we may need from you

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We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person 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.

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Time limit to respond

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We will respond to your request to exercise these rights within a reasonable time. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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11. Glossary

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PROCESSING

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Processor means any natural or legal person who processes the data on behalf of the controller.

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DATA PROTECTION LEGISLATION

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EU GDPR means the General Data Protection Regulation ((EU) 2016/679).

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LAWFUL BASIS

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Consent means processing your data where you have provided us with your explicit consent.

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Legitimate Interest means processing your data in the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

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Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

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Comply with a legal or regulatory obligation means processing your data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

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THIRD PARTIES

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External Third Parties means:

service providers acting as processors who provide IT and system administration services and marketing agencies or hosts of the systems that deliver the Platform’s functionalities;
professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances;
advertisers and advertising networks such as Google and Facebook that require the data to select and serve relevant adverts to you and others. We do not disclose Identity Information about users to our advertisers, but we may provide them with aggregated information or anonymised data about our users. We may also use such aggregated information or anonymised data to help advertisers reach the kind of audience they want to target. We may make use of personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
search engine providers such as Google that assist us in the improvement and optimisation of the Platform;
Stripe Inc is a global company we use to process your online payments to us. Their privacy policy can be accessed here https://stripe.com/gb/privacy;
Mixpanel Inc is a global company which we use to process your booking with us if you do so through our app. Their privacy policy can be accessed here https://mixpanel.com/legal/privacy-policy/;
Mailchimp is a global company which we use for email marketing. Their privacy policy can be accessed here: https://mailchimp.com/legal/privacy/;
Customer.io is a global company which we use for email marketing. Their privacy policy can be accessed here: https://customer.io/legal/privacy-policy/;
Mention Me is a global company which we use for our refer-a-friend programme and related services. Their privacy policy can be accessed here: https://mention-me.com/help/privacy_policy;
Timely is a global company which we use to process your booking with us if you do so through our website. Their privacy policy can be accessed here https://www.gettimely.com/support/privacy/;
Hubspot is a global company which we use for CRM. Their privacy policy can be accessed here https://legal.hubspot.com/privacy-policy;
Chargebee is a global company which we use for our subscription billing and revenue management. Their privacy policy can be accessed here https://www.chargebee.com/privacy/;
Intercom is a global company which we use for customer support. Their privacy policy can be accessed here https://www.intercom.com/legal/privacy; and
Segment is a global company which we use as a data warehouse. https://www.twilio.com/en-us/legal/privacy.

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12. Cookie Policy

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Our Platform uses cookies. A cookie is a small text file which is stored on your computer, tablet or phone when you visit the Platform. These cookies allow us to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our Platform and also allows us to improve our Platform.

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There are two main types of cookie:

session cookies—these are temporary files, deleted when you finish browsing a website and are not stored on your computer longer than this. The next time you visit that website, the website will not recognise you.
persistent cookies—these are stored on your computer after you have finished using a website so that the website provider can remember your actions and preferences the next time you use it.

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Cookies can be set by the website you have browsed, i.e. the website displayed in the uniform resource locator (URL) window. These are called first party cookies. Third party cookies are set by a website other than the one you are browsing.

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You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Platform may become inaccessible or not function properly.

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To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

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How do we use cookies?

to estimate our audience size and usage pattern;
to store information about your preferences, and so allow us to customise our site according to your individual interests;
to speed up your searches; and
to recognise you when you return to our site.

Consent

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If you continue to use our Platform we will assume that you are happy to receive all cookies from our Platform. However, if you would prefer to change your cookie settings, you can do so at any time—see below ‘Controlling our use of cookies’.

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Controlling our use of cookies

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Most browsers automatically accept cookies unless you change your internet browser settings. If you wish to restrict, block or delete the cookies which are set by any websites, you can generally do this through your browser settings. These settings are usually found in the ‘options’ or ‘preferences’ menu of your internet browser.

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If you set your internet browser preferences to block all cookies, you may not be able to access all or parts of our Platform.

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If you delete cookies relating to our Platform we will not remember things about you, including your cookie preferences, and you will be treated as a first-time visitor the next time you visit the site.

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If you have any questions or comments regarding our Cookies Policy, please contact us.

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