Privacy Policy
1. Who we are
This website is operated by [LEGAL NAME LTD], a company registered in England and Wales under company number [COMPANY NUMBER], with its registered office at [LEGAL ADDRESS] (referred to in this policy as “we”, “us” or “our”). We provide online education for hairdressers, barbers and cosmetologists, and remote consultations on hair and skin care.
We are the controller of the personal data described in this policy for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. You can contact us about anything in this policy by email at [EMAIL].
2. Data we collect
We collect the following categories of personal data:
- Contact details — your name, email address and, if you choose to share it, your phone number, provided when you email us about courses or consultations.
- Enquiry and enrolment details — the course track or consultation you are interested in, your professional background and your learning goals.
- Course work — photos and videos of your practice work that you submit for review and feedback.
- Consultation materials — photos of your hair, scalp or skin and the information you provide about their condition, your current routine and the products you use.
- Communications — the content of emails and video calls between you and us, including notes we make during consultations and classes.
- Payment-related information — confirmation of payments processed by our payment provider; we do not receive or store your full card details.
We do not collect data through server-side forms on this website; you contact us directly by email using the links provided.
3. Purposes and legal bases
We process personal data for the following purposes and rely on the following legal bases under Article 6 UK GDPR:
- Providing courses and consultations — responding to enquiries, enrolling you, delivering lessons, reviewing your work and answering your questions. Legal basis: performance of a contract, or steps taken at your request before entering into one.
- Processing consultation photos and condition details — preparing your personal hair or skin care recommendations. Legal basis: your explicit consent (see section 4).
- Administration and record keeping — accounting, invoicing and tax records. Legal basis: compliance with a legal obligation.
- Service improvement and communication history — keeping reasonable records of correspondence, improving course materials and handling follow-up questions. Legal basis: our legitimate interests in running and improving our services, balanced against your rights.
- Protecting our legal position — establishing, exercising or defending legal claims where necessary. Legal basis: our legitimate interests.
4. Photos and sensitive data
To provide a remote consultation we ask you to send photos of your hair, scalp or skin and to describe their condition. Information about the condition of your skin or scalp may reveal information about your health and is therefore treated as special category data under Article 9 UK GDPR.
We process this data only with your explicit consent, which we ask for before you send us any photos or condition details. If you do not give consent, we cannot provide the consultation, but this does not affect your ability to take our courses. You may withdraw your consent at any time as described in section 11, and we will stop using the material and delete it unless we are legally required to keep it.
Our consultations are cosmetic guidance, not medical advice. If your photos or description suggest a condition that needs medical attention, we will tell you and recommend that you see a doctor, trichologist or dermatologist.
5. Sharing with third parties
We do not sell personal data. We share it only with service providers who help us run our services, under contracts that require them to protect it:
- Hosting providers — companies that host this website and store our files and email.
- Payment providers — companies that process payments for courses and consultations; they handle your card details under their own privacy policies.
- Video communication platforms — services used to run live classes and consultation calls.
We may also disclose personal data where required by law, for example to HMRC, a regulator or a court.
6. International transfers
Some of our service providers may store or process data outside the United Kingdom. Where that happens, we make sure the transfer is protected by appropriate safeguards: a UK adequacy decision for the destination country, the UK International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses. You can ask us for more information about the safeguards that apply to your data by emailing [EMAIL].
7. How long we keep data
- Enquiries that do not lead to enrolment — up to 12 months from our last exchange, so we can answer follow-up questions.
- Course records and submitted work — for the duration of your course and up to 24 months after it ends, unless you ask us to delete your work earlier.
- Consultation photos and condition details — for the duration of the consultation and up to 6 months afterwards, so we can answer follow-up questions, unless you withdraw consent earlier.
- Accounting and tax records — 6 years from the end of the relevant financial year, as required by UK law.
When a retention period ends, we securely delete or anonymise the data.
8. Security
We protect personal data with measures appropriate to its sensitivity: encrypted connections to this website and to our email, access limited to the people who need it to provide your course or consultation, strong authentication on the accounts and devices we use, and prompt deletion when data is no longer needed. No online service can be completely secure, but if we become aware of a breach affecting your data, we will act in line with our obligations under UK GDPR, including notifying you and the ICO where required.
9. Cookies
This website does not set its own cookies and does not use analytics, advertising or tracking technologies. The site does not store information in your browser. If this changes, we will update this policy and, where required, ask for your consent first.
10. Your rights
Under UK GDPR you have the following rights in relation to your personal data:
- Access — to receive a copy of the personal data we hold about you.
- Rectification — to have inaccurate data corrected and incomplete data completed.
- Erasure — to have your data deleted in certain circumstances.
- Restriction — to limit how we use your data in certain circumstances.
- Portability — to receive data you provided to us in a structured, commonly used, machine-readable format.
- Objection — to object to processing based on our legitimate interests.
- Withdraw consent — to withdraw consent at any time where processing is based on it.
To exercise any of these rights, email us at [EMAIL]. We will respond within one month; we may ask you to confirm your identity first. Exercising these rights is free of charge.
11. Withdrawing consent
Where we rely on your consent — in particular for consultation photos and information about the condition of your hair or skin — you can withdraw it at any time by emailing [EMAIL]. Withdrawal does not affect the lawfulness of processing carried out before it. After you withdraw consent, we will stop the related processing and delete the material unless a legal obligation requires us to keep it.
12. Complaints
If you are unhappy with how we handle your personal data, please contact us first so we can try to resolve it. You also have the right to lodge a complaint with the UK supervisory authority, the Information Commissioner’s Office (ICO): ico.org.uk, or by phone on 0303 123 1113.
13. Age restriction
Our courses and consultations are intended for adults aged 18 or over. We do not knowingly collect personal data from anyone under 18. If you believe a person under 18 has provided us with personal data, please contact us and we will delete it.
14. Changes to this policy
We may update this policy from time to time, for example if our services or legal requirements change. The current version is always available on this page, with the date of the latest update shown at the top. For significant changes that affect how we use your data, we will inform you by email where we hold your address.