Privacy Policy

At Beauty Spot App, our mission is to bring people together and foster inclusivity within the beauty community. Our goal is clear: to create a world where everyone feels embraced and valued. Trust is foundational in all our interactions and that means being clear about how we handle your information and respecting your privacy rights.

This Privacy Policy (the “Policy”) outlines how Beauty Spot App Ltd, and its affiliates (“Company” or "us" or "we" or "our") having company registration number 13681664 collect, use, store, process, transfer, and disclose your information through our Website https://www.beautyspotapp.co.uk/ (the “Website”), Beauty Spot App (the “App”) which is available for download from the App Store and Google Play, and any of our other websites, mobile or digital applications, or any other services we offer from time to time by or in connection therewith (together referred to as the “Platform” or “Beauty Spot App”). It applies to your interactions with and usage of our Platform that allows Clients to arrange and schedule appointments for beauty-related services with Service Providers. Through our Platform, Clients can easily discover a variety of beauty services, compare options, and book appointments with Service Providers who best meet their needs, which connects individuals with a wide range of hair and beauty services, (the “Services”). For the avoidance of doubt, the hair and beauty specialists and professionals who offer, list, and book hair and beauty services are referred to as “Service Providers” and the individuals who avail themselves of such hair and beauty services are referred to as “Clients”.

Your access to or utilisation of our Platform and/or Services operated by the Company linked to this Policy implies your agreement to be governed by this Policy. By providing us with your Personal Information, you expressly consent to the use and disclosure of your Personal Information as outlined in this Policy. This Policy, along with the Terms of Service for Clients and Service Providers is applicable to your use of the Services and you explicitly agree and acknowledge to read the Privacy Policy in conjunction with the Terms of Service for Clients and Service Providers.

The term “Personal Information” shall mean any information that relates to an identified or identifiable individual, and can include information that you provide to us and that we collect about you, such as when you engage with our Services (e.g. device information, IP address).

By utilising the Services, engaging with the Company's Platform, or furnishing your Personal Information, you explicitly agree and acknowledge that you accept the terms delineated in this Policy. The terms 'you' or 'your' or ‘User’ in the context of this Policy pertains to any Service Provider, Client, or other individual or entity that accesses or interacts with the Platform.

By visiting the Platform or providing your information, you expressly agree to be bound by this Privacy Policy and agree to be governed by the privacy laws of the United Kingdom including but not limited to the United Kingdom General Data Protection Regulation (UK GDPR, General Data Protection Regulation (GDPR) and other relevant regulations governing data protection and privacy.

IF YOU DO NOT CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS SET FORTH IN THIS PRIVACY POLICY, PLEASE REFRAIN FROM ACCESSING AND/OR USING OUR PLATFORM.

1. TO WHOM DOES THIS POLICY APPLY?

1.1. This Policy is inclusive and applies to all Users of our Platform, irrespective of their browsing intent or their extent of utilising the Services offered on our Platform.

1.2. Our Platform is not intended for children under 13 years of age. No one under the age of 13 may provide any Personal Information to or on the Platform. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information on this Platform or on or through any of its features/register on the Platform, make any purchases through the Platform, use any of the interactive features of this Platform or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us on help@beautyspotapp.co.uk.

1.3. Eligible Users: Users, including both Service Providers and Clients, represent and warrant that they meet the following eligibility criteria:

You are not under the age of 13 years.
If you are over the age of 13 but under the age of 18, you have obtained your parent/guardian’s permission to access the Platform.
You are 18 years old and capable of forming a legally binding agreement.
You demonstrate the intention and capacity to utilise our Platform and/or Services

1.4. The applicability of this Policy extends to Users regardless of the device type used for accessing our Platform, whether it be a laptop/desktop or a mobile/tablet device.

2. WHAT IS THE INFORMATION THAT WE COLLECT FROM YOU?

2.1. To use our Platform, you need to create an account and register with us (“Account”) and for this purpose, we collect certain Personal Information. This may include but is not limited to the following:

2.1.1. Basic Information: You are required to provide basic information such as first name, last name, and some of which will depend on the features you use;

2.1.2. Contact information: such as email address and mobile number;

2.1.3. Linked Account Information: If your Account is linked with Google or Apple, we collect your Google or Apple email address for authentication and communication purposes;

2.1.4. Transaction Data: including the details of the payment method such as credit or debit card number, and bank account information. If you are not our Beauty Spot App User, we may receive payment information relating to you, such as when a User provides your payment card to complete a booking;

2.1.5. Data from Social Networks: User information from social networking sites, such as Facebook, Instagram, and Twitter, including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect your Account to such social networks;

2.1.6. Information about others: such as a payment instrument or contact information belonging to another person or information. By providing us with Personal Information about others, you certify that you have permission to provide that information to Beauty Spot App for the purposes described in this Privacy Policy and you have shared the Beauty Spot App’s Privacy Policy with them;

2.1.7. Additional Information: When you fill in information through our payment partner, Stripe, make payments through Stripe, add information to your Account, participate in promotions, communicate with the Beauty Spot App support team, import or manually enter address book contacts, provide your address and/or geolocation, or share your experience with us, you may choose to provide supplementary information to improve your experience. This supplementary information may be in any form, such as text, images, sound, or video. Additionally, you may choose to participate in a poll, survey, or otherwise provide feedback on the Services;

2.1.8. Content: You may provide certain information to be published or displayed on public areas of the Platform or transmitted to other users of the Platform or third parties (collectively, “Content”). Your Content is posted and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your Account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Platform with whom you may choose to share your Content. Therefore, we cannot and do not guarantee that your Content will not be viewed by unauthorised persons. You understand that when you submit reviews, upload images and videos, or provide other content to the Platform, your posts may be viewed by all Users and may be publicly distributed outside the Platform in perpetuity;

2.1.9. Communication with us: This can include any communication that you send to us, including communications for any inquiries, payments, technical support, etc;

2.1.10. Device Identification data: This includes information that may assist us in identifying your device, including login information, browser type, and version, your operating system, etc; and

2.1.11. Other Data: This can include the following, based on your interaction with the Platform-

a. Number of times you logged into your Account;

b. The length of time you spent on the Platform;

c. The period of time from which you became and have continued to be active on the Platform;

d. Other similar statistics we may collect with the intention to improve the User experience of the Platform.

2.2. Supplementary Information from Service Providers

2.2.1. After creating an Account on the Platform, the Service Provider must set up a Business Profile by providing information such as the business or company name and location of the business (full address or specific area). Service Providers who work from home, can choose to hide their full address and display only a specific area (e.g., Southwark) on their Business Profile. The full address will be sent to Clients 48 hours before their appointment;

2.2.2. Service Details: Service Providers will also be required to provide details such as a list of services offered (including service name, duration, and price), their booking and cancellation policies (cancellation notice period, deposit amount, and option for advance payment), regular working hours (e.g., Monday to Friday, 9 am to 5 pm), and blocked-off times when bookings are not available;

2.2.3. Service Provider Content: As a Service Provider on our Platform, you are required to upload at least four images and video content for the benefit of Clients. By utilising this feature, you agree to adhere to all relevant laws and regulations regarding content creation and distribution. Beauty Spot App reserves the right to review and moderate any content uploaded to ensure compliance with our community guidelines and standards. You retain ownership of any original content you upload but grant Beauty Spot App a non-exclusive, worldwide, royalty-free licence to use, distribute, and display such content on the Beauty Spot App. Additionally, you acknowledge and agree that Beauty Spot App may use your likeness, voice, and performance in promotional materials or advertising related to the Beauty Spot App. Please note that if you upload Content from a third-party cloud storage drive, you may be asked to sign in to that account and authorise us to access your files. We will only access files on your drive that you choose to upload. No third-party account credentials or user profile data belonging to you will be accessed, retained, or shared by us;

2.2.4. Please remember that any Content submitted to our Platform can be viewed by the public, 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 refer to the third party’s privacy policies to learn more about its data practices.

2.3 You agree to provide us and our Payment Processor Stripe with your Personal Information whenever you use our Services by performing any of the following functions:

2.3.1. Accessing our Platform by means of any web browser or any device;

2.3.2. Creating an Account and registering for our Services on the Platform;

2.3.3. Inquiring about our Services through our Platform;

2.3.4. Initiating and maintaining correspondence with us.

2.4. We strive to take extra precautions to ensure that such Personal Information is kept secure and confidential, and we will only retain this data for as long as necessary for the purposes for which we collect it as per the permissible laws of the land.

2.5. By using our Services, you acknowledge that you are bound by the terms and policies of our third-party service providers such as our payment processor Stripe. Adhering to their policies is crucial for safeguarding your data and ensuring compliance with industry standards. We prioritise User privacy and security by relying on trusted third-party service providers, and we encourage Users to review and understand the policies of these platforms to protect their interests.

2.6. This Policy will not apply to any unsolicited information provided by you through the Platform or through any other means. This includes but is not limited to, information posted on any public areas of the Platform. All such unsolicited information shall be deemed to be non-confidential and we will be free to use and disclose such unsolicited information without limitation.

2.7. We shall not be liable for any loss or damage sustained by you as a result of any disclosure (inadvertent or otherwise) of any Personal Information concerning your Account, credit cards, or debit cards in the course of any online transactions or payments made for any Services offered through the Platform. For this purpose, we recommend that you go through the terms of service of the payment service provider.

2.8. Access to your Personal Information is limited to employees, agents, partners, and third parties, who we reasonably believe will need that information to enable us to provide Services to you. However, we are not responsible for the confidentiality, security, or distribution of your own Personal Information by our partners and third parties (who have their own privacy policies) outside the scope of our agreement with such partners and third parties.

2.9. When you use our Platform, we collect and store your information which is provided by you from time to time. In general, you can browse the Platform without telling us who you are or revealing any Personal Information about yourself. Once you give us your Personal Information, you are not anonymous to us. Where possible, we indicate which fields are required and which fields are optional. You always have the option to not provide information by choosing not to use a particular service, product, or feature on the Platform.

3. HOW DO WE COLLECT THE INFORMATION?

3.1. We employ various methods to gather information, ensuring a comprehensive understanding of User interactions and preferences. The collection of Personal Information is facilitated through the following processes:

3.1.1. Information you give us: When you provide us with the information referred to in Clause 2.1 and 2.2 through the methods outlined in Clause 2.3;

3.1.2. Session Management: We study session metrics to understand how Users interact with the Platform. This helps us learn the average time Users spend on the Platform and when they prefer to engage. We use tools like Google Analytics (or alternatives) to collect anonymous data, including the number of views, how long Users stay, and where they're visiting from. This data allows us to optimise the User experience, making informed enhancements to cater to User preferences and behaviours; and/or

3.1.3. User analytics: We analyse User behaviour and preferences, by collecting and analysing Personal Information and maintaining transaction history within the Platform to track and ensure accuracy, promptly identify any unauthorised transactions, and detect fraudulent activities, allowing us to take immediate corrective action.

3.2 In addition to direct User interactions, we leverage cookies and similar technologies to enhance the functionality and User experience on the Platform. These allow us to collect and process additional information for various purposes:

3.2.1. Cookies: We utilise cookies, which are small text files stored on Users' devices. These cookies assist in tracking user preferences, optimising Platform functionality, and providing a customised experience. Users have the option to manage cookie preferences outlined through their browser settings. Below are the categories of cookies used on our Platform along with a description of what they are used for:

3.2.1.1. Strictly Necessary Cookies: These cookies are needed to run our Platform, to keep it secure if you are logged in, and to obey regulations that apply to us. If you are a registered User, they help us know who you are so that you can login and manage your Account. They also help us keep your details safe and private;

3.2.1.2. Functional Cookies: These cookies are used for remembering things such as your user ID on the log-in page, your region or country, your preferred language, accessibility options like large font or high-contrast pages; and

3.2.1.3. Performance Cookies: These cookies tell us how you and our other users use our Platform. We combine all this data together and study it. This helps us to improve the performance of our Services and/or the Platform; and

3.2.1.3. Targeting/Advertising Cookies: These cookies are used to deliver content more relevant to you and your interests. They may also be used to limit the number of times you see an advertisement.

3.2.2. Web Beacons, Pixel Tags, and Trackers: We may employ web Web Beacons, Pixel tags, and tracking URLs which are tiny graphic images and/or small blocks of code placed on Platform pages, ads, or in our emails that allow us to determine whether you performed a specific action. When you access these pages, or when you open an email, you let us know that you have accessed the web page or opened the email. These tools help us measure responses to our communications and improve our web pages and promotions:

3.2.3. Log Files: Our servers automatically collect information sent by Users' devices, known as log files. This data may include IP addresses, device information, browser type, and timestamps. Log files are instrumental in analysing trends, administering the Platform, and diagnosing technical issues;

3.2.4. Third-Party Analytics: We may integrate third-party analytics services to further understand User behaviour. These services utilise their own tracking technologies to compile reports on Platform activity, aiding us in improving our Services;

3.2.5. Third-Party Plugins: The Platform may use social plugins provided and operated by third parties, such as Facebook’s Like Button. As a result of this, you may send to the third party the information that you are viewing on a certain part of the Beauty Spot App. If you are not logged into your Account with the third party, then the third party may not know your identity. If you are logged in to your Account with the third party, then the third party may be able to link information or actions about your interactions with the Beauty Spot App to your Account with them. Please refer to the third party’s privacy policies to learn more about its data practices;

3.2.6. You understand that our Platform may, from time to time, contain links to and from the websites of our service providers, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any Personal Information that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any Personal Information to these websites or use these services;

3.2.7. Location Data: As part of our Services we may also collect precise geolocation data, including GPS signals, device sensors, Wi-Fi access points, and cell tower IDs. We collect this type of data if you grant us access to your location. You can withdraw your consent at any time by disabling the GPS or other location-tracking functions on your device; and

3.2.8. Information from other sources: We may collect Personal Information from other sources, including but not limited to:

3.2.8.1. If a Service Provider, Client, or any third party submits a complaint about you, we may receive information relating to the specific complaint made in order to understand and, where relevant, address the complaint; and

3.2.8.2. To the extent permitted by applicable law, we may receive additional information about you, such as references, demographic data, and information to help detect fraud and safety issues from (i) third-party service providers, other third parties, and/or partners, or (ii) any other individuals, entities, and authorities, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention, security investigation, and risk assessment efforts. We may receive information about you and your activities on and off the Beauty Spot App, including from Users of the Beauty Spot App, users of the public, or governmental, public, or tax authorities, or about your experiences and interactions from our partners.

4. WHY DO WE COLLECT YOUR INFORMATION?

4.1 We shall collect your information only for lawful and legally permissible purposes which are as follows:

4.1.1. Service Providers: To allow Service Providers to effectively manage and provide services to their Clients;

4.1.2. Contractual Necessity: We process your Personal Information to fulfil our contractual obligations to you. This includes actions such as managing bookings and delivering Services;

4.1.3 User Authentication: We collect your information to help us identify you as and when you access the Platform, when you register an Account with us or log in, or reset Account passwords or when you utilise our Services;

4.1.4. Transactions and Payments: To facilitate secure and efficient payment processing, as well as handle transactions related to Services on the Platform. Also, Personal information is utilised to enable or authorise payment services, including detecting and preventing money laundering, fraud, abuse, and security incidents, complying with legal obligations, and improving payment services;

4.1.5. Communicate with you: We use your Personal Information to communicate with you concerning Services via different channels (e.g., by phone, e-mail, chat) including fulfilling your requests or providing you with any news or updates related to Beauty Spot App or feedback or provide technical support;

4.1.6. Fraud Prevention and Credit Risks: We use Personal Information to prevent and detect fraud and abuse to protect the security of our Users;

4.1.7. Troubleshoot Problems: We use your Personal Information to provide functionality, analyse performance, fix errors, and improve the usability and effectiveness of the Platform;

4.1.8. Compliance with law: To be able to perform any contractual and legal obligation;

4.1.9. Client Testimonials: We may use your Personal Information to post client testimonials on our Platform, with your consent, to provide social proof and enhance the credibility of our products and Services;

4.1.10 Enhancing User Experience: To analyse User behaviour and preferences for improving our Services and User experience and to be able to provide location-specific services;

4.1.11. Recommendations and Personalisations: We use your Personal Information to recommend features, products, and Services that might be of interest to you, identify your preferences, and personalise your experience with the Platform;

4.1.12. Enhanced Advertising and Marketing Efforts: In our efforts to provide, personalise, measure, and enhance our advertising and marketing endeavours, we engage in several key activities. Firstly, we utilise User information to send promotional and marketing messages, tailoring them to suit individual preferences and interests. Additionally, we strive to customise and optimise advertising on various platforms to ensure relevance and effectiveness. Furthermore, we administer rewards, surveys, sweepstakes, and other promotional activities to engage Users and foster community participation. Through the analysis of User characteristics and preferences, we aim to send targeted promotional messages that resonate with each User segment. Finally, we extend invitations to Users for events and relevant opportunities, enriching their overall experience with our Platform; and

4.1.13. Providing alerts/notifications: To effectively communicate with you through emails/SMS/notifications through the Platform to inform you about any other new Services that we may from time to time develop.

4.2. In the course of operating our Platform and/or Services, we collect and utilise Personal Information in accordance with our Privacy Policy. For European Union Residents please refer to Schedule I which supplements our main Privacy Policy and outlines protections afforded to you.

4.3. You consent and recognise that your Personal Information may be disclosed on our Platform authorised by you for the purpose of utilising our Services. Additionally, you agree and acknowledge that we are permitted to communicate with you through messaging, calls, emails, or other means, to facilitate the performance of our Services wherever necessary.

5. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH AND WHY?

5.1. To facilitate our Services and enhance User experience, we may share Personal Information with the following entities-

5.1.1. Transactions: We may share your Personal Information necessary for transaction processing with our trusted financial or payment gateway partner;

5.1.2. Third-party Service Providers: We engage the services of third parties to carry out various functions on our behalf such as payment processing, data analysis, postal and email communications, hosting services, customer service, and marketing assistance. While these third-party service providers have access to the necessary Personal Information to fulfil their functions, they are prohibited from using it for any other purposes. Moreover, they are obligated to process the Personal Information in compliance with applicable laws. Further, we do not own or control these third parties. When you interact with these third parties and choose to use their service, you are providing your information to them. Your use of these services is subject to the privacy policies of those providers, including Stripe's Privacy Policy;

5.1.3. You understand that we are not responsible for the practices employed by these third party websites linked to or from our Platform nor the information or content contained therein. Please note that when you are redirected to some external website from our Platform, 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;

5.1.4. Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates may include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us;

5.1.5. Business Transfers: If we reorganise or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline to honour commitments we made in this Privacy Policy;

5.1.6. Legal Compliance:

5.1.6.1. We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, authorised third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply with our legal obligations, (ii) comply with a valid legal request, such as a subpoena or court order, or to respond to claims asserted against Beauty Spot App, (iii) respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our Users to legal or regulatory liability, (iv) enforce and administer our agreements with Users, including our Terms, additional legal terms, and policies, (v) respond to requests for or in connection with current or prospective legal claims or legal proceedings concerning Beauty Spot App and/or third parties, in accordance with applicable law, or (vi) protect the rights, property or personal safety of Beauty Spot App, its employees, its Users, or members of the public;

5.1.6.2. Where legally required or permissible according to applicable law, we may disclose Service Providers’ and/or Clients’ information to relevant tax authorities or other governmental agencies, depending on where you are based, for the purpose of the tax authorities’ determination of proper compliance with relevant tax obligations;

5.1.6.3. In jurisdictions where Beauty Spot App facilitates or requires a registration, notification, permit, or licence application or number of Service Providers with a governmental authority, we may share information about participating Service Providers with the relevant authority, during the application process, when the Listing is published, and periodically thereafter;

5.1.6.4. Where appropriate and/or legally required, we may notify Users about legal requests, unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to Beauty Spot App, our Users, or expose Beauty Spot App to a claim of obstruction of justice;

5.1.7. Service Improvement: You understand and agree that we compile anonymous statistical data and analysis for use internally or with third parties and we may share such anonymous statistical data and certain aggregated, anonymised information with third parties (for example, for Google Analytics) in order to assess the Platform usage and information pertaining to the ease of navigation;

5.1.8. Advertisements: We use third-party advertising companies to serve ads when you visit our Platform. These companies may use information (not including your name, address, email address, or telephone number) about your visits to the Platform and other websites in order to provide personalised advertisements about goods and services of interest to you. Additionally, these companies may use information contained in web cookies about your visits to the Platform and other websites to provide relevant advertisements;

5.1.9. Collaborations: We may share your Personal Information with reputable partners to facilitate joint initiatives, promotions, or integrated services;

5.1.10. Growth and Expansion: As our Platform evolves and expands, there may be instances where sharing Personal Information with new entities or parties becomes necessary for the enhancement of our Services. Any such sharing will be carried out with the utmost consideration for User privacy and in accordance with relevant legal frameworks.

5.2. We do not ever sell or rent your Personal Information without your express approval.

5.3. We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

6. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

In compliance with applicable laws, we retain your Personal Information for a duration no longer than necessary for the purpose for which it was collected or as mandated by relevant laws. You can review or modify your Account information or terminate your Account at any time by logging into your Account settings or contacting us. Upon Account termination, we will deactivate or delete your information from our active databases. However, certain information related to you may be retained beyond this period, if we reasonably believe it is necessary to prevent fraud, mitigate potential abuse, allow us to exercise our legal rights, defend against legal claims, or fulfil other legitimate purposes required by law or for analytical and research purposes. You understand that, we may continue to retain your Personal Information for the following purposes including but not limited to:

6.1. Legitimate Business Interest: We may retain your Personal Information as necessary for our legitimate business interests, such as the prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend your Account for fraud or safety reasons, we may retain information from that Account to prevent that User from opening a new Account in the future;

6.2. Legal, Tax, Reporting, and Auditing Obligations: We may retain and use your Personal Information to the extent necessary to comply with our legal, tax, reporting, and auditing obligations;

6.3.Shared Information: Information you have shared with others, such as reviews and forum postings, may continue to be publicly visible on the Beauty Spot App, even after your Beauty Spot App Account is cancelled; and

6.4. Residual Copies: Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your Personal Information (either in the form of De-Identified Information, Non-Identifying Information, or identified information) may not be removed from our backup systems for a limited period of time. However, Users understand and agree that sometimes it will be impractical for User information to be de-identified or treated in this way, and in this case, Beauty Spot App will continue to use and hold the information in a personally identifiable state. For example, if we need to reply to a User enquiry we will have to use the contact information provided.

7. HOW DO WE PROVIDE FOR THE SECURITY OF YOUR PERSONAL INFORMATION WITH US?

7.1. We prioritise the security of your data, utilising secure cloud servers, where your Personal Information is encrypted at rest, adding an extra layer of protection against unauthorised access. Additionally, we adhere strictly to industry best practices for all data transfers, ensuring that your information remains secure during transmission. We implement reasonable physical, electronic, and procedural safeguards to ensure the confidentiality and integrity of your information. Accessing your Account information is facilitated through a secure server, and once in our possession, your data is subject to strict security guidelines to prevent unauthorised access.

7.2. While we take comprehensive measures to safeguard your information, Users acknowledge and accept the inherent security implications of data transmission over the Internet and the World Wide Web. Despite our efforts, complete security cannot be guaranteed, and inherent risks persist. Users bear the responsibility of safeguarding login and password records for their Accounts. We remain committed to continually enhancing our security protocols to address emerging threats and maintain the trust of our Users.

8. HOW DO WE HANDLE DATA BREACHES AND SECURITY INCIDENTS?

8.1. In the event of a data breach or security incident, the Beauty Spot App maintains a proactive approach to ensure swift resolution and mitigate potential risks. We have established a comprehensive incident response plan designed to address such occurrences promptly and effectively:

8.1.1. Identification: We promptly identify and acknowledge any signs of a data breach or security incident within our systems or infrastructure;

8.1.2. Containment: Immediate action is taken to contain the impact of the breach, preventing further unauthorised access or damage to data;

8.1.3. Notification: We prioritise transparency by promptly notifying affected parties, including Users and relevant stakeholders, about the breach and its potential impact on their data;

8.1.4. Collaboration: We collaborate with relevant authorities, such as regulatory bodies and law enforcement agencies, to report the incident and comply with any legal obligations or regulatory requirements; and

8.1.5. Post-Incident Assessment: Following the resolution of the incident, we conduct thorough assessments to evaluate the effectiveness of our response measures and identify areas for improvement.

9. DO WE TRANSFER YOUR PERSONAL INFORMATION CROSS-BORDER?

9.1. While our primary practice is to store all data on servers located within the United Kingdom, it's important to note that certain circumstances may necessitate the transfer of your Personal Information to countries outside your residential country. These transfers may occur for various purposes outlined in this Policy.

9.2. You understand and accept that other countries may have differing (and potentially less stringent) laws relating to the degree of confidentiality afforded to the information it holds and that such information can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies, and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar processes. In addition, a number of countries have agreements with other countries providing for the exchange of information for law enforcement, tax, and other purposes.

9.3. If we transfer your Personal Information to third parties for purposes stated in this Policy, we will use our best endeavours to put in place appropriate controls and safeguards to ensure that your Personal Information is kept accurate, adequately protected, and processed only for specified and reasonable purposes in a manner that is fair, transparent and has a lawful basis, and is stored for no longer than is absolutely necessary

10. WHO IS THE CONTROLLER OR PROCESSOR OF YOUR DATA?

10.1. We will act as the data controller where we make decisions on how your Personal Information is used in connection with the Platform or our Services. We will act as the data processor where we only use your Personal Information as authorised and instructed by a third party in connection with the website, or our applications or services.

10.2. Where we are acting as the data controller, we are responsible for the obligations of a data controller under data protection laws in connection with the processing of your Personal Information and we use this Privacy Policy to provide you with information about our use of your Personal Information.

10.3. Where we are acting as a data processor, the relevant third party will be acting as a data controller and will be responsible for the obligations of a data controller under data protection laws in connection with the processing of your Personal Information. If you are accessing the Platform, or our Services through a third party, you should contact them with queries regarding the processing of your Personal Information or compliance with data protection law.

11. WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?

11.1. You, as a data subject, have certain rights to your Personal Information with us, as under:

11.1.1. You have the right to receive a copy of the Personal Information we hold about you.

11.1.2. You have the right to correct the Personal Information we hold about you.

11.1.3. Where applicable, you may also have a right to receive a machine-readable copy of your Personal Information.

11.1.4. You also have the right to ask us to delete your Personal Information or restrict how it is used. There may be exceptions to the right to erasure for specific legal reasons which, if applicable, we will set out for you in response to your request. Further, if you delete your Content from the Platform, copies of your Content may remain viewable in cached and archived pages or might have been copied or stored by other Platform Users.

11.1.5. Where applicable, you have the right to object to the processing of your Personal Information for certain purposes.

11.1.6. Where you have provided us with consent to use your Personal Information, you can withdraw this consent at any time.

11.1.7. You can opt out of marketing communications such as newsletters, emails, or other messages from us by: (a) Noting your preferences when you register your Account on the Platform, (b) logging into your Account settings and updating your preferences, or (c) contacting us using the contact information provided below.

11.1.8. Furthermore, we offer electronic newsletters to which you may voluntarily subscribe at any time. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. You understand that even if you opt out of marketing emails, we will continue to send you transactional emails about your purchases.

11.1.9. Additionally, we may request to send you push notifications regarding your Account or on the Platform. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

11.1.10. 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.

11.1.11. If you would like to exercise any of your rights specified above, please email help@beautyspotapp.co.uk We will respond to all standard 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 large number of requests. In this case, we will notify you and keep you updated.

11.1.12. We may need verification of your identity to proceed with a request. If you provide us with proof of identity containing information that does not match our records, we may request further proof of identity from you. This is a security measure to ensure that your Personal Information is not disclosed to any person who has no right to receive it.

11.1.13. You will not have to pay a fee to obtain a copy of your Personal Information (or to exercise any of the other rights). However, for any further copies requested by you, we may charge a reasonable fee based on administrative costs.

12. ARE CHILDREN ALLOWED TO USE OUR PLATFORM AND/OR SERVICES?

12.1. This Platform is strictly prohibited for use by individuals under the age of eighteen (13) years old ("Minors"). Accessing or using the Platform by Minors constitutes a violation of our Terms of Service and Privacy Policy.

12.2. We do not knowingly solicit, collect, or process any Personal Information from Minors. We implement commercially reasonable age verification measures and data protection practices to prevent such unauthorised collection and usage.

12.3. If you are a parent or legal guardian ("Guardian") and believe your child has provided us with Personal Information, we urge you to promptly contact us at help@beautyspotapp.co.uk. Upon verification of your Guardian status, we will promptly take all necessary steps to remove and delete such information from our records.

13. REPORT COMPLAINTS AND CONCERNS

User satisfaction is one of the key focus areas and an integral part of our Platform’s founding principles and business policies. We strongly believe that User satisfaction is the most important factor in the growth and development of our business and hence, we have adopted User-centricity as a priority in developing our business processes. The terms below shall constitute our “User Grievance Redressal Policy” which outlines the framework for addressing User grievances:

13.1. Objective: The objective of this Grievance Policy is to provide a framework:

13.1.1. to ensure the provision of timely and effective resolution of issues raised by Users; and

13.1.2. to keep Users informed about the manner in which they can reach out to us to resolve their queries and grievances.

13.2. Governing Principles: The policy on grievance redressal is governed by the following principles:

13.2.1. User shall be treated fairly at all times;

13.2.2. Issues raised by Users are always attended to with courtesy and on time;

13.2.3. Users are provided with effective and satisfactory resolution within a reasonable time period; and

13.2.4. Users are fully informed of avenues to escalate their issues/ grievances if they are not fully satisfied with the response to their complaints.

13.3. User Support: Any User can reach out to us for any and all privacy-related matters and to assist in ensuring our compliance with our privacy obligations. This can be done through electronic mode by way of email communication at help@beautyspotapp.co.uk and the Privacy Offer will respond to your query or complaint as quickly as possible.

13.4. We will contact you if we require any additional information from you and will notify you in writing (which includes electronic communication via email) of the relevant determination.

13.5. Must Know: You must know and understand that:

13.5.1. We DO NOT solicit confidential details like your OTP/CVV/PIN/Card Number/ Bank account details through any means. We never call our Users with offers, discounts on Services, and offering free gifts.

13.5.2. Scamsters/fraudsters attempt various techniques such as ‘phishing’, to contact, influence, and defraud Users. We regularly caution our Users against sharing any personal or payment-sensitive information with unknown persons as such sharing leads to unauthorised use and/or fraud and consequent financial loss.

13.5.3. We shall not be liable for any loss, damage, or expense incurred by a User where the User has shared personal and/or payment-sensitive information with scamsters/fraudsters.

13.5.4. Additionally, we also request and encourage our Users to report such attempts or incidents to us at help@beautyspotapp.co.uk to enable us to investigate and explore legal recourse.

13.5.5. We rely on payment partners and banks. In certain cases involving payment/refund issues, we might see a delay as that is beyond our control once we pass the investigation to them; however, we try our best not to exceed reasonable timelines.

14. HOW ARE CHANGES MADE TO THIS POLICY?

This Policy may be updated at our sole discretion or due to changes in the law. Such changes, unless otherwise stated, will be effective from the day and date of posting on the Platform. We reserve the right to update the Policy without obligation to notify Users. It is recommended to regularly review this Policy for any changes, as your continued access and use of the Platform will be considered your approval and acceptance of all modifications to this Policy. In cases where applicable law mandates, we may notify you of updates through email. If you do not agree with this Policy governing our Platform, please refrain from using the Platform or the Services provided by us.

15. HOW CAN YOU CONTACT US?

Should you need additional information or have any questions or complaints regarding the handling of your Personal Information, please reach out to us in writing at:

help@beautyspotapp.co.uk

Schedule I- European Union Residents

Beauty Spot App is committed to ensuring its compliance with the European Union General Data Protection Regulation (‘GDPR’).

Although our Privacy Policy explains how Beauty Spot App meets all of its obligations for United Kingdom Users, Beauty Spot App also has some Users who are habitually located in the European Union (‘EU Residents’) that have additional rights in respect of their Personal Data.

Personal Data is defined as: “Any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier”.This should be considered fundamentally interchangeable with the expression “Personal Information” for the purposes of this Privacy Policy.

Under the GDPR, Beauty Spot App is primarily a “controller” of Personal Data, as opposed to being a “processor”. As part of its GDPR compliance, Beauty Spot App provides the Services in a way that ensures: Personal Data (i.e. Personal Information) is processed fairly, lawfully, and in a transparent manner; and collected and processed only for specified and lawful purposes.

We ensure that the Personal Information we collect about you is accurate, complete, and used for its intended purpose. You may access, review, correct, and update your Information or close your Account by contacting us by email at the contact details below.

EUROPEAN UNION RESIDENTS

In certain circumstances, you have certain rights regarding your Personal Information. A summary of each right and how you can exercise it is detailed below. To exercise any of these rights, please contact us at help@beautyspotapp.co.uk. Such requests should include information to allow us to verify your identity (e.g. your name, address, email address or other information reasonably required).

Where we receive your request to exercise one of these rights, we will respond without undue delay and within the time required by applicable law. This may be extended in certain circumstances, e.g. where requests are complex or numerous.

We will provide the information free of charge, except where requests are manifestly unfounded or excessive, e.g. because of their repetitive character. In these circumstances, we may charge a reasonable fee or may refuse to act on the request. We will advise you of any fees prior to proceeding with a request. We may ask for additional information to verify your identity before carrying out a request.

HOW CAN YOU EXERCISE RIGHT?

1. Right to access and/or correct your Personal Information

You have the right to access the Personal Information we hold about you, and to be provided with a copy of the information (in most circumstances). You also have the right to correct any information we may hold about you that is inaccurate.

2. Right to restrict the use of your Personal Information

You have the right to ask us to restrict the processing of your Personal Information where one of the following applies:

The processing is unlawful, but you want us to restrict the use of the data instead of deleting it;
Where you contest the accuracy of your Personal Information, the restriction will apply until we have verified the accuracy or corrected your Personal Information;
We no longer require the Personal Information for the purposes of the processing, but are required to keep it in connection with a legal claim;
You have exercised your right to object to the processing. The restriction will apply until we have taken steps to verify whether we have compelling legitimate grounds to continue processing.

3. Right to withdraw consent and request deletion of your Personal Information

You have the right to ask us to delete your personal information in most circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the Personal Information is required to comply with a legal obligation or for the establishment, exercise, or defence of legal claims.
You may object to our use of your Personal Information for marketing purposes. Users can opt out of this through the functionality provided in each marketing communication (e.g. by clicking “unsubscribe” at the bottom of an email).
Further, You may also object to the processing of your Personal information in cases where we have used legitimate interests as the basis for processing. In such cases, we will stop processing your Personal Information until we verify that we have compelling legitimate grounds for processing that outweigh your interests, rights, and freedoms in asking us to stop processing the data, or in limited cases where we need to continue processing the data for the establishment, exercise, or defence of legal claims.

4. Right to data portability

In most cases, you have the right to receive all Personal Information you have provided to us in a structured, commonly used, and machine-readable format and to transmit this data to another data controller, where technically feasible.

5. Right to lodge a complaint with a supervisory authority

If you wish to raise a complaint in relation to how we processed your Personal Information, please contact us at help@beautyspotapp.co.uk We take your privacy and data protection very seriously in Beauty Spot and we endeavour to address your complaint as expediently and as thoroughly as we can in order to find a satisfactory resolution for you.

Beauty Spot App will allow and assist Users who are EU Residents to exercise these rights unless we have compelling and legitimate legal grounds not to (e.g. a legal obligation under United Kingdom legislation, or if the Personal Information has been fully anonymised).