Styles & Me

INTRODUCTION

Welcome to the Styles and Me’s ​ privacy​ ​ policy​ .
Styles and Me respects your ​ privacy and is committed to protecting your personal ​ data​ . This ​ privacy ​ policy will inform you as to how we look after your personal ​ data when you visit our website (regardless of where you visit it from) and tell you about your privacy​ rights and how the law protects you.
This ​ privacy​ ​ policy​ is provided in a layered format so you can click through to the specific areas set out below and is available on www.stylesandme.com. Alternatively, you can request a pdf version of the ​ policy​ by emailing stylesandmeuk@gmail.com​

Please also use the Glossary to understand the meaning of some of the terms used in this ​ privacy​ ​ policy​ .

  • [​ IMPORTANT INFORMATION AND WHO WE ARE ​ ] ​
  • [​ THE DATA WE COLLECT ABOUT YOU ​ ]
  • [​ HOW IS YOUR PERSONAL DATA COLLECTED? ] ​
  • [​ HOW WE USE YOUR PERSONAL DATA ​ ]
  • [​ DISCLOSURES OF YOUR PERSONAL DATA ​ ]
  • [​ INTERNATIONAL TRANSFERS ​ ]
  • [​ DATA SECURITY ​ ]
  • [​ DATA RETENTION ​ ]
  • [​ YOUR LEGAL RIGHTS ​ ]
  • [​ GLOSSARY ] ​

1. IMPORTANT​ ​ INFORMATION​ ​ AND​ ​ WHO​ ​ WE​ ​ ARE

This ​ privacy ​ policy aims to give you information on how Styles and Me (S&M) collects and processes your personal ​ data through your use of this website, including any ​ data​ you may provide through this website or when you use our App. This website is not intended for children and we do not knowingly collect ​ data relating to children. It is important that you read this ​ privacy ​ policy together with any other ​ privacy ​ policy or fair processing ​ policy 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 privacy​ ​ policy​ supplements other notices and ​ privacy​ ​ policies​ and is not intended to override them.

CONTROLLER

STYLES AND ME LTD of 102 Fortune Gate Road, London, United Kingdom, NW10 9RG is the controller and responsible for your personal ​ data​ (collectively referred to as ”Styles and Me” (S&M), “we”, “us” or “our” in this ​ privacy​ ​ policy​ ).S&M is the controller and responsible for this website. We have appointed Mr Alfie Oliver Payne as ​ data ​ privacy manager and he is responsible for overseeing questions in relation to this ​ privacy ​ policy​ . If you have any questions about this ​ privacy ​ policy​ , including any requests to exercise [​ your Data Rights] ​ , please contact the ​ data​ ​ privacy​ manager using the details set out below

CONTACT DETAILS

If you have any questions about this ​ privacy ​ policy or our ​ privacy practices, please contact our [DPO ​ OR ​ data ​ privacy manager] in the following ways: Full name of legal entity: Styles and Me Limited Email address: s tylesandmeuk@gmail.com You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK 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 ​ PRIVACY​ ​ POLICY​ AND YOUR DUTY TO INFORM US OF CHANGES

We keep our ​ privacy ​ policy under regular review. This version was last updated on 30​ th April 2020. Historic versions are archived here: or can be obtained by contacting us.

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

This website 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 our website, we encourage you to read the ​ privacy ​ policy of every website you visit.

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, last name.
  • Contact ​ Data​ includes billing address, delivery address, email address and telephone numbers.
  • Financial ​ Data​ includes bank account and payment card details as provided to create PayPal Accounts.
  • Transaction ​ Data – We do not monitor, store, collect or otherwise process any personal data related to transaction or purchase history.
  • 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 this website.
  • Profile ​ Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage ​ Data​ – We do not monitor your usage of our website.
  • Marketing and Communications ​ Data​ – We do not monitor or collect your marketing preferences.

We do not collect any ​ Special Categories of Personal ​ Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric ​ data​ ). Nor do we collect any information about criminal convictions and offences. Insofar as photographs of people’s faces and hair are uploaded to our website, app or interface these images are not uploaded for the benefitof S&M but rather our Member Hairstylists and End-user Consumers. Additionally, the photographs are not being collected for biometric purposes of identifying any living individual but rather to show different hairstyles or beauty products & treatments provided from our Member Hairstylists to promote to their end user Consumers. We do not collect nor process any hair or face samples for identification nor biological analysis relating to inherited or acquired genetic characteristics of any natural person.

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 but we will notify you if this is the case at the time. You would have agreed to us collecting and processing your personal data when you created an S&M account or downloaded our S&M App in our T&C’s of the App or Account.

3.​ ​ HOW​​ IS​​ YOUR​​ PERSONAL​​ DATA​​ COLLECTED?

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

Direct interactions. You may give us your Identity, Contact and Financial ​ Data by creating an online account with us or downloading our app and creating an S&M account. This includes personal ​ data​ you provide when you

  • apply for our products or services;
  • create an account on our website or on our app
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • give us feedback or contact us.

Automated technologies or interactions.

As you interact with our website, we will 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 https://stylesandme.com/privacy-policy.html​ for further details.

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

(a)​ analytics providers such as Google based outside the EU;
(​ b ​ ) Amazon Webserver with servers based in the US and EU.

  • Contact, Financial and Transaction ​ Data from providers of technical, payment and delivery services such as PayPal based outside the EU in the US.
  • Identity and Contact ​ Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest Retention Period
To register you as a new customer and/or Member/Subscribing Hairdresser (a) Identity
(b) Contact
Performance of a contract with you 6 years from the deactivation date of your account on our app
To process and deliver your order including: a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
Transaction
(e) Marketing and Communications
(c) Legal Obligation to comply with our (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Legal Obligation to comply with ou tax Obligations with Her Majesty’s Revenue Commission and to ensure we can bring or Defend any claims arising against u 6 years from the deactivation date of your account on our app
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (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 customers use our products/services) and bringing or defend any claims arising against us. 6 years from the deactivation date of your account on our app
Linking our Member/Subscriber
Hairdressers with End-User
Customers
Linking End-User Customers with
Hairdressers, Hairdresser’s products,
Services and styles
(e) Managing Accounts of our Users
Marketing & Promotions TBA TBA TBA
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (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 6 years from the deactivation date of your account on our app
To deliver relevant website 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 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) 6 years from the deactivation date of your account on our app
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) 6 years from the deactivation date of your account on our app
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications Necessary for our legitimate interests (to develop our products/services and grow our business) 6 years from the deactivation date of your account on our app

We will only use your personal ​ data when the law allows us to. Most commonly, we will use your personal ​ data in the following circumstances: • Where we need to perform the contract we are about to enter into or have entered into with you. • Where 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 obligation. Click here [LINK TO GLOSSARY, LAWFUL BASIS] 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 although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL ​ DATA

We have set out above, 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 above

MARKETING

We strive to provide you with choices regarding certain personal ​ data uses, particularly around marketing and advertising. If you feel that your current marketing preferences are not working for you and/or you would like to discuss changes, please feel free to contact us for a chat by emailing us at ​ stylesandme@gmail.com​ .

PROMOTIONAL OFFERS FROM US

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). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal ​ data​ with any third party for marketing purposes.

OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal ​ data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

COOKIES
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 ​ https://stylesandme.com/privacy-policy.html​ .

CHANGE OF PURPOSE
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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 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. 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.

5.​ ​ DISCLOSURES​ OF​ YOUR​ PERSONAL​ DATA

We may share your personal ​ data with the parties set out above for the purposes set out in the table [​ Purposes for which we will use your personal ​ data ] ​ above.

  • Internal Third Parties as set out in the [​ Glossary ​ ].
  • External Third Parties as set out in the [​ Glossary ] ​ .
  • Our End-User Customers and the General Public accessing or viewing our website or downloading our app.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. 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 ​ privacy​ ​ policy​

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.

6.​ ​ INTERNATIONAL​ TRANSFERS

TRANSFERS OUT OF EEA OCCUR: We share your personal ​ data within PayPal and Amazon. This will involve transferring your ​ data​ outside the European Economic Area (​ EEA​ ).
Many of our external third parties are based outside the EEA so their processing of your personal ​ data will involve a transfer of data​ outside the EEA.
Whenever we transfer your personal ​ data out of the 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. For further details, see ​ European Commission: Adequacy of the p ​ rotection of personal d ​ ata ​ in non-EU countries ​ .
  • 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. For further details, see ​ European Commission: Model contracts for the transfer of personal ​ data ​ to third countries . ​
  • Where we use providers based in the US, we may transfer ​ data to them if they are part of the ​ Privacy Shield which requires them to provide similar ​ protection to personal ​ data shared between Europe and the US. For further details, see ​ European Commission: EU-US ​ Privacy ​ Shield . ​

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

7.​ ​ DATA​ ​ SECURITY

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. 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.

8.​ ​ DATA​​ RETENTION

HOW LONG WILL YOU USE MY PERSONAL ​ DATA​ FOR? We will only retain your personal ​ data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, 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.
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, regulatory, tax, accounting or other requirements. Details of retention periods for different aspects of your personal ​ data​ are available in our retention ​ policy​ which you can request from us by contacting us at ​ stylesandmeuk@gmail.com​ ​ and ​ set out in the table [​ Purposes for which we will use your personal data] ​ above.
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. Whilst we will only store your personal data as long as you maintain your app and/or account with us, we will be required to hold the personal data for six years after the date in which you terminate your account or app with us for tax purposes.
In some circumstances you can ask us to delete your ​ data​ : see [​ your legal rights ​ ] below for further information. In some circumstances we will 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.

9.​ ​ YOUR​ LEGAL RIGHTS

Under certain circumstances, you have rights under ​ data ​ protection laws in relation to your personal ​ data​ . Please click on the links below to find out more about these rights:

  • [​ Request access to your personal ​ data ] ​ .
  • [​ Request correction of your personal ​ data ] ​ .
  • [​ Request erasure of your personal d ​ ata ​ ].
  • [​ Object to processing of your personal ​ data ​ ].
  • [​ Request restriction of processing your personal ​ data ] ​ .
  • [​ Request transfer of your personal ​ data ] ​ .
  • [​ Right to withdraw consent ​ ].

If you wish to exercise any of the rights set out above, please contact us on​ ​ stylesandmeuk@gmail.com​ .

NO FEE USUALLY REQUIRED

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 could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU
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.

TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could 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.

Specific uses of information you provide to us

9. Information provided on the understanding that it will be shared with a third party

Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.

Examples include:

  • posting a message our forum
  • tagging an image
  • clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks

In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.

We do not specifically use this information except to allow it to be displayed or shared.

We do store it, and we reserve a right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted.information that you have posted. You can make a request by contacting us at alfie@stylesandme.com or stylesandme.com/contact.

10.​ ​ GLOSSARY

Data Controller ​ means an entity or individual who collects, stores, processes or otherwise uses or handles personal data belonging to a living individual for that entity’s or individual’s benefit. Such entity should be registered with the Information Commissioners Office as such.
Data Processor ​ means an entity or individual who collects, stores, processes or otherwise uses or handles personal data belonging to a living individual on behalf of and/or for another entity’s or individual’s benefit.
Data Protection Officer (DPO) - means an individual registered with the Information Commissioners Office (ICO) as a Data Protection Officer (if applicable) and who maintains the responsibility and duties within an organisation for taking administrative decisions regarding personal data practices for that organisation and also making decisions as to how to resolve Data Rights Complaints on a case-by-case basis as raised by the Data Subjects against a Data Controller.

Personal Data ​ means data which is capable of identifying any living individual whether directly or indirectly.

LAWFUL BASIS
Legitimate Interest means 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.

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.

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

THIRD PARTIES

INTERNAL THIRD PARTIES

S&M and its employees and affiliates.

EXTERNAL THIRD PARTIES

  • Service providers acting as processors based in the US and EU who provide IT and system administration services and payment services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom 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].
  • Our subscribing member Hairdressers and End-user Customers who have created accounts using our website or app online interface.
  • Other contractors who provide goods and supply services to S&M.

YOUR LEGAL RIGHTS

You have the right 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 the 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 a 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 of your personal ​ data​ . This enables you to ask us to suspend the processing of your personal data​ in the following scenarios

  • If you want us to establish the ​ data’s​ accuracy.
  • Where our use of the ​ data​ is unlawful but you do not want us to erase it.
  • 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.
  • You have objected to our use of your ​ data​ but we need to verify whether we have overriding legitimate grounds to use it.

Request the 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 that 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.
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. We will advise you if this is the case at the time you withdraw your consent.