Simple Salon Group Pty Ltd – Privacy Policy

This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through this website and mobile application (Site). In this Privacy Policy we, us or our means Simple Salon Group Pty Ltd ABN 37 611 937 501. When we collect, store and use your personal information, we do so in accordance with the rules set down in the Australian Privacy Act 1988 (Cth) and by the European Union General Data Protection Regulation (EU) 2016/679 (the GDPR).

Personal information

The types of personal information or personal data we may collect about you include:

  • your name;
  • your contact details, including email address, mailing address, street address and/or telephone number;
  • your age and/or date of birth;
  • your credit card and/or bank account details;
  • your demographic information, such as postcode;
  • your preferences and/or opinions;
  • information you provide to us through customer surveys;
  • details of products and services we have provided to you and/or that you have enquired about, and our response to you;
  • your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
  • information about your access and use of our Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
  • additional personal information that you provide to us, directly or indirectly, through your use of our Site, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
  • any other personal information requested by us and/or provided by you or a third party.

We may collect these types of personal information directly from you or from third parties.

Collection and use of personal information

We may collect, hold, use and disclose personal information for the following purposes:

  • to enable you to access and use our Site, associated applications and associated social media platforms;
  • to contact and communicate with you;
  • for internal record keeping and administrative purposes;
  • for analytics, market research and business development, including to operate and improve our Site, associated applications and associated social media platforms;
  • to run competitions and/or offer additional benefits to you;
  • for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;
  • to comply with our legal obligations and resolve any disputes that we may have; and
  • to consider your employment application.

We collect personal information in a variety of ways, including:

Directly: We collect personal information which you directly provide to us, including when you register for an account, through the ‘contact us’ form on our website or when you request our assistance via email, or over the telephone.

Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.

From third parties: We collect personal information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.

Legal bases for processing (for European Economic Area users)

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable European Union laws. The legal bases depend on the services you use and how you use them. This means we collect and use your personal information only 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;
  • it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services and to protect our legal rights and interests;
  • you give us consent to do so for a specific purpose (for example we might ask for consent in order to provide you with our services, provide customer support and personalised features); or
  • we need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using our services.

Disclosure of personal information to third parties

We may disclose personal information to:

  • third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
  • our employees, contractors and/or related entities;
  • our existing or potential agents or business partners;
  • sponsors or promoters of any competition we run;
  • anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
  • credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
  • courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
  • third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Australia including in the United States of America; and
  • third parties to collect and process data, such as Google Analytics or other relevant businesses. This may include parties that store data outside of Australia including in the United States of America.
  • all the below third parties categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

The third party will only process your personal information in accordance with written instructions from us and we require that the third party either complies with the privacy shield principles set out in the GDPR or another mechanism set out by applicable EU & Swiss data protection laws for the transfer and processing of personal information. When we refer to ‘processing’ in this clause and this Privacy Policy in general, we mean any operation or set of operations which is performed on personal information, whether or not by automated means, such as collecting, recording, organising, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available personal information.

Please note that we use the following third parties to process your personal information:

  • Xero Accounting
  • Stripe Payments
  • PIN Payments
  • MailChimp
  • Campaign Monitor
  • SMS Central
  • Burst SMS
  • SMS Global
  • Cloudinary
  • Google Cloud
  • Slick.

Overseas Disclosure

We may store personal information in countries outside of where you are based, such as Australia. Further, where we disclose your personal information to the third parties listed above, these third parties may store, transfer or access personal information outside of Australia or the EEA.

Where the disclosure of your personal information is subject to Australian privacy laws (but not subject to the GDPR), unless we seek and receive your consent to an overseas disclosure of your personal information, we will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the Australian Privacy Principles and/or we will take such steps as are reasonable in the circumstances to require that overseas recipients protect your personal information in accordance with the Australian Privacy Principles.

Where the disclosure of your personal information is subject to GDPR, the countries to which we send data for the purposes listed above may be less comprehensive that is what is offered in the country in which you initially provided the information. Where we transfer your personal information outside of the country where you are based, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal information in accordance with this Privacy Policy. This includes:

  • only transferring your personal information to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal information; or
  • including standard contractual clauses in our agreements with third parties that are overseas.

How we treat personal information that is also sensitive information

Sensitive information is a sub-set of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation, sexual practices or sex life, criminal records, health information or biometric information. In the EEA, sensitive information is usually referred to as Special Categories of Data.

Provided you consent, your sensitive information may only be used and disclosed for purposes relating to the primary purpose for which the sensitive information was collected.

Sensitive information may also be used or disclosed if required or authorised by law.

We do not actively request sensitive information, or Special Categories of Data about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.

Your rights and controlling your personal information

Choice: Please read this Privacy Policy carefully. By providing personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. If you are under 16 years of age, you must have; and warrant to the extent permitted by law to us that you have, your parent or legal guardian’s permission to access and use the Site and they (your parents or guardian) have consented to you providing us with your personal information. You do not have to provide personal information to us, however, if you do not, it may affect your use of this Site or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access and data portability: You may request details of the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party (data portability).

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints: If you believe that we have breached the Australian Privacy Principles or an article of the GDPR and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. If you are not happy with how we are processing your personal information, you have the right to make a complaint at any time to the relevant Data Protection Authority based on where you live. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Authority, so please contact us in the first instance using the contact details set out below.

Anonymity: where practicable, we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures such as the pseudonymisation and encryption of personal information, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Cookies and web beacons

We may use cookies on our Site from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our Site with personal information, this information may be linked to the data stored in the cookie. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

We may use web beacons on our Site from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

Google Analytics

We have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, Google Display Network Impression reporting. We and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.

You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

Personal information from social network accounts

If you connect your account with us to a social network account, such as Facebook, or Google, we will collect your personal information from the social network. We will do this in accordance with the privacy settings you have chosen on that social network.

The personal information that we may receive includes your name, ID, user name, handle, profile picture, gender, age, language, list of friends or follows and any other personal information you choose to share.

We use the personal information we receive from the social network to create a profile for you on our platform.

Where we have accessed your personal information through your Facebook account, you have the right to request the deletion of personal information that we have been provided by Facebook. To submit a request for the deletion of personal information we acquired from Facebook, please send us an email at the address at the end of this Privacy Policy and specify in your request which personal information you would like deleted. If we deny your request for the deletion of personal information, we will explain why.

Links to other websites

Our Site may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy. We will notify you if we amend this Privacy Policy, by contacting you through the contact details you have provided to us. Any amended Privacy Policy is effective once we notify you of the change.

For any questions or notices, please contact our Privacy Officer at:

Simple Salon Group Pty Ltd ABN 37 611 937

Email: support@simplesalon.com

Last update: 14 September 2022