Privacy Notice for Hair Adviser Website
Last updated: Nov 11, 2024
Intro
Sugesta L.L.C. (“we”) welcomes you. This Privacy Notice (“Privacy Notice”) applies to our website (“Hair Adviser” or “Website”), available following the link.
The Privacy Notice describes which of your personal data we collect, how we store, process, and use it, and what happens when you use the Website.
About us
We are a controller of your personal data processed through the Website. This means that we determine the purposes and means of personal data processing.
About you
When you visit the Website, you become our user (“User”).
We divide the Users into categories so you can easily find details about the processing of your personal data. Pay attention that you can fall into several categories depending on your actions.
| Type of User | Description |
|---|
| Newsletter Subscriber | User who has subscribed to the newsletter within the “Subscribe” or “Sign Up” forms |
| Support Requester | User who fills out the “Contact us” form |
| AI User | User who uses AI functionality to create new hairstyles for him- /herself |
| Feedback Provider | User who provides feedback to us on using the services |
| Please note! We do not knowingly process the personal data of Users under the age of 16. If you are such a User or the legal representative of such a User, please contact us. |
Personal data
Sources of data
We receive your data when you visit the Website and interact with it, depending on your actions on the Website.
You can change your personal data on the Website by exercising your right to rectification or by the Website’s functionality. Please note that the same lawful basis and storage terms apply to the changed data.
We may also receive data from third parties. It depends on your settings and the features you use.
Lawful bases for processing
To process your personal data, we rely on the following lawful bases:
- performance of the contract — for the processing of personal data necessary for the negotiating on, conclusion, and performance of a contract (mainly, the Terms of Use) with you;
- legitimate interest — for the processing necessary for the development of our services, taking into consideration your interests, rights, and expectations;
- consent — for additional specific purposes.
Users’ data
When you visit the Website, we collect some data automatically. We collect some technical data about the Users to optimize performance, debug issues, and enhance features while ensuring security and privacy to improve the overall user experience.
Most of the technical data we collect are anonymous, but some data is associated with your IP address and device ID. Please read about personal technical data below.
| Data | Reasons for processing | Lawful basis |
|---|
| Information about the сoarse location (IP address, country) | The optimization of the performance, debugging, enhancement of the features’ proper functioning, and improvement of the Website | Legitimate interest |
| Technical device information and network information (including IP address, HTTP user agent, HTTP referrer) |
| Data storage |
| We store the data for 3 years from its collection. |
We also need cookies to operate, support, and improve the Website’s functionality.
| Data | Description | Reasons for processing | Lawful basis |
|---|
| Necessary cookies | Information that is necessary for the operation of the Website | Improving your experience of using the Website | Performance of the contract |
| Marketing cookies | Marketing information used to match relevant advertising to you | Marketing | Consent |
| Preference cookies | Information necessary for operating some services on the Website | The operation of some services on the Website | Consent |
| Data storage |
| We store the data during the expiry period provided in the Cookie Policy |
Newsletter Subscriber’s data
We collect some of your personal data when you fill in the “Subscribe” or “Sign Up” forms on the Website.
| Data | Reasons for processing | Lawful basis |
|---|
| Email | To provide you with expert articles and other required content | Consent |
| Data storage |
| We store the data until you withdraw your consent. |
Support Requestors’ data
We collect some of your personal data when you register on the Website.
| Data | Reasons for processing | Lawful basis |
|---|
| Name | To personalize our response to your request | Performance of the contract |
| Email | To respond to your request |
| Subject of your message | To fulfill your request |
| Text of your message |
| Data storage |
| We store the data for 3 years after the termination of the Terms of Use |
AI Users’ data
We collect some of your personal data when you use AI functionality to create new hairstyles for yourself.
| Data | Reasons for processing | Lawful basis |
|---|
| Email | To respond to your request and create an account for you | Performance of the contract |
| Type of pack | To choose the type of subscription |
| Age | To personalize your request |
| Photo |
| Data storage |
| We store the data for 3 years after the last interaction with us |
Please note! We do not transfer this data to any third parties and do not use your photos for identification purposes.
Feedback Providers’ data
We collect some of your personal data when you share your feedback on using our services with us.
| Data | Reasons for processing | Lawful basis |
|---|
| Text of the feedback | To improve our services | Legitimate interest |
| Data storage |
| We store the data for 3 years after the collecting data |
Data received from third parties
We may receive some personal data from third parties.
The amount of data collected, the purposes, and the lawful basis for processing are determined by the respective privacy documents of these third parties.
Data sharing with third parties
We can share your personal data with third parties without any harm to you and in full compliance with applicable law. In addition, we have implemented organizational and technical measures to ensure the security of personal data during data transfer to third parties.
| Third parties | Description |
|---|
| Analytics tools | We use analytics tools to understand and promote our business. |
| Messengers | We use messengers to communicate with you in ways that are convenient for you. |
| Contractors and services providers on the Website | We cooperate with service providers and contractors to provide you with their services, operate, develop, and improve the features and functionality of the Website, fulfill your support requests, complete payment transactions, etc. |
| Providers of the services our team uses | We use CRM systems, messengers, and other services in our organisation to provide you with our services. |
| State authorities, courts, law enforcement agencies, etc | We may be obliged to transfer some of your data to tax authorities, courts, law enforcement agencies, and other governmental bodies:- to comply with a government request, court order, or applicable law;
- to prevent unlawful use of the Website;
- to protect against claims of third parties;
- to help prevent or investigate fraud.
|
| To get a detailed list of the third-party recipients of your personal data, contact us. |
To share your data, we rely on the following lawful bases, depending on the case: consent, compliance with the law, and performance of a contract.
Data Sharing Outside the European Economic Area
The personal data we collect is stored on the US servers, which participate in the Data Privacy Framework and European Economic Area (“EEA”) servers, which fall under the General Data Protection Regulation.
We may share personal data with the recipients in the USA and other countries, including non-EEA ones, ensuring that your data is protected and processed in accordance with the General Data Protection Regulation.
To share the data outside the EEA, we rely on the adequacy decision by the European Commission or the Data Privacy Framework participation of the recipient.
If the recipient does not participate in the Data Privacy Framework and its country is not deemed to provide an adequate level of protection for your personal data, we adopt Standard Contractual Clauses based on legislation assessments for data protection during transfer and storage.
You can read more detailed measures to protect your personal data here
Data protection
We apply security measures appropriate to the possible risks.
| Organizational measures |
| Staff training | Internal policies and instructions |
| Non-disclosure agreements (NDA) |
| Technical measures |
| Backups |
Data subjects’ rights
You, as a data subject (individual), have the right to interact with your data directly or through a request to us. This section describes these rights and how you can exercise them depending on your residency.
European Economic Area and United Kingdom residents
You, as a data subject, have the right to interact with its data directly or through a request to us. This section describes these rights and how you can exercise them:
| Right | Description |
|---|
| Right to access | You can request an explanation of the processing of your personal data. |
| Right to rectification | You can change the data if it is inaccurate or incomplete. |
| Right to erasure | You can send us a request to delete your personal data from our systems. We will remove them unless otherwise provided by law. |
| Right to restrict the processing | You may partially or completely prohibit us from processing your personal data. |
| Right to data portability | You can request all the data you provided to us and request to transfer data to another controller. |
| Right to object | You may object to the processing of your personal data. |
| Right to withdraw consent | You can withdraw your consent at any time. |
| Right to file a complaint | If your request is not satisfied, you can file a complaint with the regulatory body. |
| To exercise your rights, contact us. |
| For EEA residents: We will answer your request within one month. If your request is not satisfied, you can submit a complaint to your local Data Protection Authority. You may find it here. |
| For UK residents: We will answer your request within one month. If your request is not satisfied, you can submit a complaint at the Information Commissioner’s Office via number 0303-123-1113 or go online at http://www.ico.org.uk/concerns. |
United States residents
Your rights vary depending on the state of your residency, as indicated below.
| Right | Description | Area |
|---|
| Right to access | You can request an explanation of the processing of your personal data. | - California;
- Colorado;
- Connecticut;
- Delaware;
- Indiana;
- Iowa;
- Montana;
- Tennessee;
- Texas;
- Utah;
- Virginia.
|
| Right to correct | You can change the data if it is inaccurate or incomplete. | - California;
- Colorado;
- Connecticut;
- Delaware;
- Indiana;
- Montana;
- Tennessee;
- Texas;
- Virginia.
|
| Right to delete | You can send us a request to delete your personal data from our systems. | - California;
- Colorado;
- Connecticut;
- Delaware;
- Indiana;
- Iowa;
- Montana;
- Tennessee;
- Texas;
- Utah;
- Virginia.
|
| Right to portability | You can request all the data you provided to us and request to transfer data to another controller. | - California;
- Colorado;
- Connecticut;
- Delaware;
- Indiana;
- Iowa;
- Montana;
- Tennessee;
- Texas;
- Utah;
- Virginia.
|
| Right to opt out of sales | The right to opt out of the sale of personal data to third parties. | - California;
- Colorado;
- Connecticut;
- Delaware;
- Indiana;
- Iowa;
- Montana;
- Tennessee;
- Texas;
- Utah;
- Virginia.
|
| Right to opt out of certain purposes | The right to opt out of processing for profiling/targeted advertising purposes. | - Colorado;
- Connecticut;
- Delaware;
- Indiana;
- Montana;
- Tennessee;
- Texas;
- Utah;
- Virginia.
|
| Right to opt out of the processing of sensitive data | The right to opt-out of processing of sensitive data. | |
| Right to opt in for sensitive data processing | The right to opt in before processing sensitive data. | - Colorado;
- Connecticut;
- Delaware;
- Indiana;
- Montana;
- Tennessee;
- Texas;
- Virginia.
|
| Right against automated decision-making | A prohibition against a business making decisions about a consumer based solely on an automated process without human input | - California;
- Colorado;
- Connecticut;
- Delaware;
- Indiana;
- Iowa;
- Montana;
- Tennessee;
- Texas;
- Virginia.
|
| Private right of action | The right to seek civil damages from a controller for violations of a statute. | |
To exercise your rights, contact us.
We will answer your request within 30 to 60 days, depending on the state and legislative requirements. If your complaint is not satisfied, you can submit a complaint to the Federal Trade Commission. |
| Please note! Some states do not have privacy laws. The rights of residents of such states are governed by U.S. federal law. If your state is not on the list, please contact us. |
Do not sell my personal information
California residents have the right under the California Consumer Privacy Act (“CCPA”) to opt out of the “sale” of their personal information by a company governed by the CCPA.
We do not sell your personal information to anyone nor use your data as a business model.
However, we support CCPA by allowing California residents to opt out of any future sale of their personal information. If you would like to record your preference that we will not sell your data in the future, pleasecontact us.
Do-not-track requests
California residents visiting the Website may request that we do not automatically gather and track information about their online browsing movements across the Internet.
Such requests are typically made through web browser settings that control signals or other mechanisms that allow consumers to exercise choice regarding collecting personal data about an individual consumer’s online activities over time and across third-party websites or online services.
We currently do not have the ability to honor these requests. We may modify this Privacy Notice as our abilities change.
Canada Residents
| Right | Description |
|---|
| Right to access | You can request an explanation of the processing of your personal data. |
| Right to rectification | You can change the data if it is inaccurate or incomplete. |
| Right to delete | You can send us a request to delete your personal data from our systems. We will remove all data except what we are obliged to store in compliance with the law requirements. |
| Right to data portability | You can request all the data you provided to us and request to transfer data to another controller. |
| Right to object opt-out | You may object to the processing of your personal data. |
| Right to withdraw consent | You can withdraw your consent at any time. |
| Right not to be subject to automated decision-making | You can object to being subject to automated-based processing to know if there are consequences concerning them due to such processing. |
| Right to lodge a complaint | If your request is not satisfied, you can file a complaint to the regulatory body. |
| To exercise your rights, contact us. |
| We will answer your request within 30 days. If your complaint is not satisfied, you can submit a complaint to the Office of the Privacy Commissioner of Canada. |
Australia Residents
| Right | Description |
|---|
| Right to access | You can request personal information held about you, except where the law allows them to refuse your request. |
| Right to rectification | You can ask for your personal information that is incorrect to be corrected. |
| Right to be deidentified | You can have the option of not identifying yourself or of using a pseudonym in certain circumstances. |
| Stop receiving unwanted direct marketing | You can request not to receive direct marketing communications and for that organization not to disclose your personal information to others for direct marketing purposes. |
| Right to lodge a complaint | If you think we mishandled your personal information, make a complaint about us to the Office of the Australian Information Commissioner. |
| To exercise your rights, contact us. |
| We will answer your request within 30 days. If your complaint is not satisfied, you can submit a complaint to the Office of the Australian Information Commissioner. |
Cookies
We use cookies that are needed for the Website’s operation. By using cookies, we receive automatically collected data. You can read more in the Cookie Policy.
If you want to turn off cookies, you can find instructions for managing your browser settings at these links:
Privacy Notice updates
The Privacy Notice is developed according to the General Data Protection Regulation, other applicable privacy laws, and best privacy practices.
Existing laws and requirements for the processing of personal data are subject to change. In this case, we will publish a new version of the Privacy Notice on the Website.
If there are material changes to the Privacy Notice or the Website that affect your data privacy rights, we will notify you by displaying information on the Website and, if necessary, ask for your consent.
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