Last updated on: 21/06/2023

PRIVACY POLICY

Salonkee SA is a Public Limited Company (“naamloze vennootschap” / “société anonyme – SA”) under Luxembourg law, whose registered office is located at Centre Orchimont, 36-38 Rangwee, L-2412 Luxembourg and which is registered with the Luxembourg Trade and Companies Register under number B207855 (“Salonkee” or “we”). References to “you” and “your” are to persons external to Salonkee (users of our Website, clients, prospects, suppliers and job applicants).

This Privacy Policy is intended to inform you about the processing of personal data that takes place via Salonkee’s Website (https://www.salonkee.lu) (“Website”) or the use of our contact details referenced on the Website (e-mails, phone numbers, post). This Privacy Policy must be read in conjunction with the Cookie policy, which can be found here: https://salonkee.lu/cookie_policy. This Privacy Policy applies only to the processing of data of physical persons, not of legal persons.

If you have further questions about this Website or about this Privacy Policy, you may contact contact.null@salonkee.salonkee.com.

This Privacy Policy may be modified, for example, in connection with new features on the Website or to comply with new legal, contractual or administrative obligations. We therefore recommend that you regularly consult this Privacy Policy. Important changes will be announced on our Website. This version of the Privacy Policy was last modified on the date referred to above.

The protection of your personal data is really important to us. We will ensure that your personal data is processed safely and lawfully, and always in accordance with applicable data protection legislation, and in particular with the General Data Protection Regulation (“GDPR”).

Content

1. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?

1.1

Salonkee is the controller, in the meaning of the GDPR, for the processing of your personal data.

2. WHAT PERSONAL DATA DO WE PROCESS?

2.1

We will process directly identifying information about you when you provide us with such personal data (for example, through a contact form on one of the pages on our Website our via e-mail) or when you contact us directly by e-mail, phone or chat.

2.2

Such personal data can include the following information:

  • if you create an account on our Website: your name, email address, gender, date of birth, address, phone number, your company. If you create an account via Facebook, we also get access to your Facebook profile photo;
  • payment information in order to pay for products and/or services on the Website and transaction history. We receive this information from our payment service providers;
  • if you are a job applicant, your current role and name of your employer, the industry sector where you work, your CV and cover letter. Please refer to our recruitment privacy policy here: https://salonkee.lu/recruitment-policy.
  • if you visit our website, our cookie policy (https://salonkee.lu/cookie_policy) applies.
  • if you contact us via email or Intercom (the communication tool on the bottom right of our website), we keep a record of this conversation. This allows us to better assist you in future exchanges;
2.3

We will also process certain non-directly identifying data when you visit our Website, such as the type of browser you are using, the operating system you are using, your IP address, etc.

3. WHY DO WE PROCESS YOUR DATA AND UNDER WHICH LEGAL BASIS?

3.1

For the technical and functional management of the Website.
We process personal data for the technical and functional management of our Website and to make the Website easy to use. By using your data, we can check how our Website is used and we can improve its content and layout. This data also allows us to adequately secure our Website. We also conduct internal research and analysis to see how our platform, products and services are used and how our business operates.
For this, we can process data such as your IP address, the pages you visit, the browser you are using, the sites you visited earlier, and the time and duration of your visit. We do this, for example, by using cookies. More information about the use of cookies can be found in our Cookie Policy to be found here: https://salonkee.lu/cookie_policy.
We process this data based on the legitimate interest of Salonkee in providing a well-functioning and secure Website.

3.2

To provide you with our services and manage your account.
If you are one of our clients, we process your personal data to provide you with the services you requested us to perform as well as to send you our invoice.
To this end, we can process data such as your name, your mobile number, your gender, your address, your e-mail address, your payment information.
We process this information for the performance of the contract with you. Without your personal data, we cannot perform the contract and provide you with our services.

3.3

To contact you.
We process your personal data to contact you by email, telephone, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, appointments, products or contracted services, including the security updates, when necessary or reasonable for their implementation. We process this information for the performance of the contract with you. Without your personal data, we cannot perform the contract or provide you with our services.

3.4

To keep you informed of our services and activities and for direct marketing.
We process your personal data to keep you informed of our activities, for example, with our newsletter and legal updates, invitations to seminars, workshops or other events.
To this end, we can process data such as your name, your job, your company name, your address, your e-mail address and your preferred language.
We process this information based on our legitimate interests to keep our prospects or clients informed of our activities and services. You can object to this processing of your personal data at any time (see point 6).

3.5

To answer your questions.
If you ask us a question by telephone, via a contact form on the Website or by e-mail, we will process your personal data in order to answer that question.
For this, we can process data such as your name, your contact information, your correspondence with Salonkee, and any other personal data you provide that may be relevant to answering your question.
We process this information based on our legitimate interests to keep our prospects or clients informed of our activities and services. You can object to this processing of your personal data at any time (see point 6).

3.6

To make contact in the context of a selection and recruitment process.
When you apply for a job through the Website or by e-mail, we process your personal data in order to contact you and to follow up your application.
For this, we can process data such as your name, your contact information, your correspondence with Salonkee, your resume, and other documents you provide us with.
The processing of your personal data for this purpose is based on your request to take steps prior to entering into a contract. Please also refer to our recruitment privacy policy here: https://salonkee.lu/recruitment-policy.

3.7

To comply with our legal and regulatory obligations.
If you are a client of Salonkee, we have to comply with certain legal and regulatory obligations such as with respect to anti-money laundering, KYC declarations and sanction checks. We must also comply with our tax and accounting obligations.
For this, we can process data such as your name, your contact information, your correspondence with Salonkee and your financial data.
The processing of your personal data for this purpose is based on the need for Salonkee to respect a legal obligation we need to comply with.

3.8

Handling our own disputes.
We may process your personal data to handle our own disputes and protect and enforce our rights.
For this, we can process data such as your name, your contact information, your correspondence with Salonkee and your financial data.
The processing of your personal data for this purpose is based on our legitimate interests consisting in being able to safeguard our rights in the event of disputes.

4. WHO HAS ACCESS TO YOUR PERSONAL DATA?

4.1

Website Hosting.
Salonkee makes use of Amazon Web Services (AWS) to manage and host the Website. Salonkee has entered into a processing agreement with such entities.

4.2

Analytics.
We may use third-party service providers to monitor and analyze the use of our Website.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.

4.3

Social media.
Our Websites allows you to follow us on social media channels, e.g., Facebook, LinkedIn and Twitter. We do not use these buttons to share your personal data with social media providers. When you click on a follow button, the relevant social media provider will gather your personal data directly from you. Please read the privacy notice of any social media provider with which you intend to share your personal data.

4.4

Payment providers.
We may provide paid products and/or services within the Website. In that case, we use third-party services from Adyen (Rokin 491012 KK The Netherlands) for payment processing (e.g. payment processors).
The Privacy Policy of our payments provider Adyen can be viewed here (https://www.adyen.com/policies-and-disclaimer/privacy-policy).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal data is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
When you use our Website to pay for a product and/or service credit card, debit card, digital wallet or other payment methods, we may ask you to provide information to facilitate this transaction and to verify your identity.

4.5

Other third parties.
We may share your personal data with:

  • (sub)contractors for assisting us in fulfilling the purposes listed above;
  • service providers: to monitor and analyze the use of our Website, for payment processing, or to contact you.
    For example: you can receive an appointment reminder message via SMS within 24 hours before your appointment by our external service providers Spryng (Quellinstraat 49 2018 Antwerpen, Belgium). You can deactivate this SMS feature by logging into your Salonkee profile or by indicating to the partner salon that you no longer wish to receive this type of service.
  • our partners, of which you request services: to manage and finalize your booking. This information is intended for internal use and, at your request, for the administration of loyalty or marketing programs.
  • ICT Service Providers and APIs: to be able to communicate with you on the site or via email/SMS in a secure and confidential manner;
  • affiliates, such as our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us. We will require those affiliates to honor this Privacy Policy;
  • our accountants, auditors, lawyers or similar advisers when we ask them to provide us with professional advice;
  • the bar authorities, judicial, police or administrative authorities if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, a binding decision of an administrative authority or a court order;
  • investors and other relevant third parties in in the event of a potential sale or other corporate transaction related to Salonkee;
  • other Website users: when you share personal data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

Salonkee will only share your personal data with these third parties provided that they comply with GDPR if they act as independent controllers, or based on a data processing agreement if they act as processors. For a detailed list of these third parties, please contact us by e-mail at contact.null@salonkee.salonkee.com, or by post to Centre Orchimont, 36-38 Rangwee, L-2412 Luxembourg.

5. WHERE DO WE STORE YOUR PERSONAL DATA?

5.1

Salonkee uses AWS services as it’s hosting provider. Data processing is carried out by: Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, Luxembourg 1855, Luxembourg (a subsidiary of Amazon.com Inc., 410 Terry Avenue North, Seattle WA 98109, USA). All data is stored at AWS servers located in Frankfurt am Main (with potential backups at AWS Paris or AWS in Amsterdam), and we will not transfer your personal data to countries outside the European Economic Area except (i) at your request, or (ii) to the extent necessary for the institution, exercise or substantiation of a legal claim. In the context of the use of some software applications, personal data may however be temporarily transferred to countries outside the Economic European Area. In such a case, an adequate level of protection is provided through the use of the European Commission's Standard Clauses.
You can find more information on the data protection of the service provider here: https://aws.amazon.com/de/privacy.

6. HOW DO WE PROTECT YOUR PERSONAL DATA AND HOW LONG DO WE KEEP YOUR PERSONAL DATA?

6.1

Salonkee takes reasonable security measures to protect your personal data from destruction, loss, modification or any other unauthorized processing. In addition, our employees and contractors who provide services related to our information systems are required to respect the confidentiality of personal information held by us. However, we cannot be held responsible for events resulting from unauthorized access to your personal information, in the case of irreverent user behavior.

6.2

Salonkee does not store your personal data for longer than necessary for the purposes for which it is stored. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The retention periods applied by Salonkee take into account the laws and regulations which impose a specific retention period for certain categories of data, as well as the recommendations of the CNPD concerning certain types of data processing. These retention periods can be up to the statutory limitation period of 10 years for all commercial matters. We may also archive your data until the expiry of the statutory limitation periods (up to 30 years in some cases), for reasons directly related to the establishment, exercise or defense of a legal claim.

6.3

We will also retain Usage Data (i.e. data collected automatically, either generated by the use of the Website or from the Website infrastructure itself for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website, or if we are legally obligated to retain this data for longer time periods.

6.4

If you would like to find out how long we keep your personal data for a particular purpose you can contact us by e-mail at contact.null@salonkee.salonkee.com, or by post to Centre Orchimont, 36-38 Rangwee, L-2412 Luxembourg.

7. WHAT RIGHTS DO YOU HAVE AND HOW CAN YOU EXERCISE YOUR RIGHTS?

7.1

Your rights:

  • You have the right to access your personal data. This allows you to find out which personal data we process about you.
  • You have the right to correct your personal data. This allows you to correct or complete incorrect or incomplete personal data that we process about you.
  • You have the right of deletion of your personal data. This allows you to permanently delete the personal data we process about you. We are not always obliged to delete your personal data at your request - this right only applies in the cases and to the extent provided for by law.
  • You have the right to limit the processing of personal data relating to you. This allows you to freeze our use of your personal data without deleting it. We are not always obliged to limit the processing of your personal data at your request - this right only applies in the cases and to the extent provided for by law.
  • You have the right to object to the processing of your personal data. This allows you to object to the further processing of your personal data. We are not always obliged to accept your objection - this right only applies if we process your personal data on the basis of our legitimate interest.
  • You have the right to withdraw your consent when the processing of your personal data takes place on the basis of your consent. Withdrawal of your consent does not affect the lawfulness of the processing based on consent before withdrawal.
  • You have the right to object to certain types of processing, on grounds relating to your particular situation, at any time insofar as that processing takes place for the purposes of legitimate interests pursued by us or by a third party. We will be allowed to continue to process your personal data if we can demonstrate “compelling legitimate grounds for the processing which override your interests, rights and freedoms” or we need this for the establishment, exercise or defense of legal claims. You can always object to the processing of your personal data for direct marketing purposes.
7.2

In order to process your request, we may ask you to provide us with the following:

  • your name and email address;
  • a photocopy of your passport or national identity card, to verify your identity;
  • the reason why you wish to exercise your right of access, correction, limitation, deletion, objection, limitation or portability with regard to your personal data or to withdraw your consent, if applicable;
  • your signature and the date of the request;

You can direct your request based on the above rights and your complaints at contact.null@salonkee.salonkee.com, or by post to Centre Orchimont, 36-38 Rangwee, L-2412 Luxembourg.

By using our Website, you consent to our collection and use of your personal information in the manner set out in this Privacy Policy. This Privacy Policy replaces any previously adopted policy. We may change this policy at any time, so please check our website regularly for any updates. If you do not agree to any of the changes, we advise you to stop using our Website and the services in question.

Salonkee S.A. 38, Rangwee L-2412, Luxembourg
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