WELLMONDE PRIVACY POLICY

15.10.2018

1. GENERAL INFORMATION

Our Privacy Policy explains how we collect, record, organize, storage, adapt, transfer, retrieve, use, destruct or otherwise process Wellmonde Users’ (hereinafter Users) personal data when providing Wellmonde Services.

Wellmonde Services are further described in Wellmonde Terms of Use (hereinafter ‘Terms of Use’), available here. Capitalized terms used but not defined herein have the meanings assigned to them in the Terms of Use.

Personal data means any information relating to an identified or identifiable natural person.

According to the Terms of Use, Wellmonde Services are solely available for registered Users, who have created User accounts through Wellmonde site. Each User shall have access and use Wellmonde Services solely through a special Wellmonde interface created for that particular User type. The scope of processing of personal data of and by each User depends on the User type.

There are four (4) types of Users, as further described in Terms of Use:

- Private Users;
- Partner Salons/Spas;
- Brands;
- Specialist.

The manner and purpose of collection and use of personal information in connection with Users` access to and use of the Wellmonde Services and Wellmonde’s responsibilities in connection with processing of the personal data is described below.

2. DATA CONTROLLER

Data controller alone or jointly with other data controller, determines the purposes and means of the processing of personal data.

When this Privacy Policy mentions “Wellmonde”, “we”, “us” or “our”, it refers to the following company who is responsible for Users’ personal data under the current Privacy Policy:

Kuruson Oy (Ltd)
Business ID: 2725130-1
Messilän kartano, Messiläntie 108, 15980 MESSILÄ, Finland

Contact person:
Mare Kuruson
mare@wellmonde.com
skype: Mare Kuruson

3. DATA PROTECTION OFFICER

The Data Protection Officer is an independent officer who will ensure that we process the personal data of Wellmonde Users in compliance with the applicable data protection rules.

Our Data Protection officer is:


Mare Kuruson
mare@wellmonde.com
skype: Mare Kuruson

4. REASON AND LEGAL BASIS FOR DATA PROCESSING

The basis for processing personal data is your consent and/or our legitimate interests (e.g. customer relationship management) and/or performance of the contract for the provision of Wellmonde Services.

More specifically, reasons for processing your personal data is:

• the delivery and development of Wellmonde Services,
• fulfilling our contractual and other promises and obligations,
• taking care of the customer relationship.
• analyzing and profiling behaviour of a customer or other data subject,

The Wellmonde Service is designed and intended for use solely by adults, therefore by subscribing to Wellmonde Services each User must confirm its maturity.

5. WHERE DO WE RECEIVE INFORMATION?

Personal data that is processed in connection with the provision of Wellmonde Services has either been received from the Users (Clauses 6.1 to 6.4) or collected by use by means of tracking of the usage of Wellmonde Services through Wellmonde sites (Clause 6.5).

6. WHAT DATA IS PROCESSED ABOUT EACH USER AND HOW

6.1. PRIVATE USER’S PERSONAL DATA

We process following private user´s personal data:

(a) Basic information such as name*, date of birth, gender and profile photo or other image.
(b) Contact information such as e-mail address*, phone number, address.
(c) Information on wellness customership such as appointments*, beauty treatment history*, feedback to the Specialist* and product reviews*.
(d) Private wellness information such as medical conditions (in form of confirmation (yes/no) of the historical presence or absence of 24 medical conditions), home beauty routine (i.e. daily habits regarding the personal use of specific brand hygiene products at various times during the day), Specialist’s notes about your beauty treatments (including skin condition).
(e) Login information such as username and/or other identifying identifier* and password*.

Committing personal data marked with a star, is a requirement for our contractual and/or customer relationship. Without necessary information we are not able to provide Wellmonde Service.

The purpose of processing the above personal data is to enable Private Users to store and maintain such personal and contact information, treatment history and product recommendations in single secure online database, so that Private Users can keep track of, update and share such information insofar as they deem necessary with Specialists, and Partner Salon/Spas for facilitating better wellness services to Private Users.

You may access, view, edit and delete (insofar as possible for maintaining of the profile) all and any of your personal data at any time. Your personal data may be shared with other Users solely in the following manner:
- Basic information, contact information and information on wellness customership may solely be viewed by a Specialist and Partner Salon/Spa to whom you have granted your profile access by ticking a check box in the relevant section in your profile page.
- Private wellness information may solely be viewed by a Specialist to whom you have granted the access to such information by ticking a check box in the relevant section in your profile.

Please note that you may at any time terminate sharing your profile and/or granting access to your private wellness information by unticking a relevant check box in the relevant section in your profile, whereafter such information is no more visible, stored or otherwise available for a such a Specialist or, Partner Salon/Spas.

Please be kindly aware that Partner Salon/Spas may also wish or be entitled to collect, store and process your private data received from you directly or other legal basis and separately from Wellmonde services in their own databases and/or client management software or otherwise for the purposes of maintaining your customer relationship and/or provision of wellness services. For any such data the corresponding Partner Salon/Spa is a data controller and any questions you may arise regarding for such processing of personal data you should apply directly to them.

Therefore, we advise that you check the privacy policy of the particular Partner/Salon Spa before giving your consent to the Partner Salon/Spa for such processing of your personal data and/or using their services.

For the sake of clarity, we wish to emphasize that such processing by the Partner Salon/Spa occurs independently from Wellmonde Services and Wellmonde undertakes no control nor any responsibility with regard to such processing of your personal data.

6.2. PRIVATE DATA RELATED TO PARTNER SALON/SPA USER

We process the following personal data about Partner Salon/Spa’s representatives:

(a) Basic information such as name*, date of birth, gender, profile photo or other image.
(b) Contact information such as e-mail address, phone number, job title, name of business and business address.
(c) Private background information such as place of residence, education and profession.
(d) Login information such as username and/or other identifying identifier and password.

The purpose of processing the above personal data is to identify the persons, who are entitled to use Wellmonde Services on behalf of the Partner Salon/Spa and creation of anonymous, aggregated statistical data about the usage of products and services by such Partner Salon/Spa.

The above private data may be entered, viewed, edited and deleted (insofar as possible for maintaining of the profile) by the authorized representative of Partner Salon/Spa. The above private data is not made public not shared with any other User.

6.3. PRIVATE DATA RELATED TO BRAND

We process the following personal data about Brand’s representative(s) is processed:

(a) Basic information such as name*, date of birth, gender, profile photo or other image.
(b) Contact information such as e-mail address, phone number, job title, name of business and business address.
(c) Private background information such as place of residence, education and profession.
(d) Login information such as username and/or other identifying identifier and password.

The purpose of processing the above personal data is to identify the persons, who are entitled to use Wellmonde Services on behalf of the Brand and is not made public not shared with any other User.

The above private data may be entered, viewed, edited and deleted (insofar as possible for maintaining of the profile) by the authorized representative of the Brand. The above private data is not made public not shared with any other User.

6.4. SPECIALIST’s PRIVATE DATA

The following private data about a Specialist may be processed:

(a) Basic information such as name*, date of birth, gender, profile photo or other image.
(b) Contact information such as e-mail address, phone number, job title, name of business (relevant Partner Spa/Salon) and business address.
(c) Information on professional activity such as appointments, relevant education and feedback to the Specialist by a Private User.
(d) Login information such as username and/or other identifying identifier and password.

The purpose of processing the above personal data is to identify the Specialist, its qualifications and certifications to use certain products and treatments and facilitate efficient and customer-friendly provision of wellness services to the Private Users.

The above private data may be entered, viewed, edited and deleted (insofar as possible for maintaining of the profile) by a Specialist. The above private data may be shared as follows:

- Basic information, contact information and information professional activity are shared with the Partner Salon/Spa, who has invited the Specialist to join Wellmonde network.
- Basic information, contact information and information professional activity (other than appointments and feedback) are shared with the Brand, which has issued its certifications to such a Specialist.
- Basic information, contact information and information professional activity (other than appointments) are shared with a Private User, who has shared its profile with the Specialist.

6.5. TECHNICAL DATA WE COLLECT THROUGH THE USE OF WELLMONDE SERVICES & USE OF COOKIES

We may use cookies, pixels and similar tracking technologies to collect data about Users when you accessing and using Wellmonde Services for the purposes of analyzing User behavior, improvement Wellmonde Service and for statistical purposes. Tracking involves the processing of login data (e.g. date and time of the visit, referrer, IP address, [cookie ID], location data, product and version information about the browser or app used, device ID or data) and interaction data (e.g. pages viewed or searches carried out). [When we measure user behaviour for the provision and improvement of our product experience the data is linked during the analysis with your user ID. In all other cases tracking is carried out without any linking to the user ID – for example, to measure the success of advertising campaigns or for statistical purposes.]

[We use the web analysis tool Google Analytics, developed by Google Inc. ("Google"). Google Analytics uses so-called "cookies": text files that are saved on your computer and enable the analysis of your usage of a website. The information generated by the cookie about your use of this website (including your IP address) is transferred to a server of Google in the USA and saved there. [We use the so-called "anonymizeIp()" script here, which ensures that your IP address (after identifying the geolocation) is immediately anonymised by Google.] We have also signed closed a data processing agreement with Google. Google will use this information to evaluate your use of the website, to compile reports about website activity for website operators, and to provide other services relating to website and online usage. Google may also pass this information on to third parties if this is required by law or if these third parties process the data on behalf of Google. Google will not link your IP address to any other data about you it has stored.

[You can prevent the installation of cookies by adjusting the settings in your browser software accordingly; please note though that you may not be able to use all the features of the XING Websitesin full as a result. Google also offers so-called deactivation tools for some web browsers, where you can opt out of your user behaviour being recorded and analysed. You will find more information and download options for these tools here: http://tools.google.com/dlpage/gaoptout?hl=en-GB].

7. CONFIDENTIALITY OF DATA

No User should copy, reproduce, transmit, store, disclose, display or otherwise use on any other media any private data of other User’s that has been made available to it when using Wellmonde Services. If such private data has been made available to a User by another User, such data should be kept strictly confidential and cannot be disclosed to anybody else in whatsoever manner.

Notwithstanding the foregoing, nothing stated in this Privacy Policy should be deemed as a prohibition or limitation preventing Partner Salon/Spa’s to separately process Private User’s data by different means and media (e.g. via Salon/Spa’s customer database) subject to separate consent of the Private User or other legal basis as explained under Clause 5.1.

8. DEVELOPING AND SHARING OF THE STATISTICAL DATA AMONG THE PROFESSIONAL USERS AND PROFILING

Please note that Wellmonde also generates and delivers aggregate anonymous statistical data on usage of products and treatments among different types of anonymous user groups to Professional Users.

For that purposes Private User’s private data about the usage of the beauty treatments, products may be grouped based on the gender, age, skin condition and location of the person. Such data will always be anonymized and no private user whose data has been used for profiling will never be subjected to any individual actions or consequences as a result of the profiling.

9. TO WHOM WE DISCLOSE AND TRANSFER DATA AND DO WE TRANSFER DATA OUTSIDE OF THE EU OR EEA?

We do not disclose data to third parties otherwise than as explained hereinafter.

We use sub-contractors on our behalf to process data for the purposes of providing website hosting and IT-management services.

Data may be disclosed to authorities under compelling provisions.

Given that Wellmonde Services are offered globally and for the purposes of providing Wellmonde Services the personal data may be transferred outside of the EU/EEA by virtue of the private user’s granting the access to its private data in accordance with clause 6.1 to Partner Salons/Spas and Specialists located in a third county outside of EU/EEA or by virtue of sharing the Specialist’s data with other users in accordance with 6.4 located in a third county outside of EU/EEA.

10. CLOSING A PROFILE AND PERIOD OF STORAGE OF DATA

After accepting Terms and conditions, Private User can choose to allow an access or not to give an access to his/her profile.

Should any User wish to delete all his/her profile from Wellmonde, it should send an e-mail to team@wellmonde.com and during one week the profile is closed and the private data about the User is not any more used for the provision of Wellmonde Services. Notwithstanding the above the name of the specialist remains visible to all Users also beyond the termination of the specialist account.

We shall continue to store the personal data [what] of [how] also after the closure of your profile for three (3) or for a longer period if required by law after the end of our customer relationship in order to comply with our legal and regulatory obligations, or to allow us to maintain evidence of our respective rights and duties. Upon expiration of this time limit, your personal data will be deleted or permanently anonymized.

11. USERS OTHER RIGHTS RELATED TO DATA PROCESSING

11.1 Right to withdraw consent and prohibit direct marketing

You may at any time withdraw consent related to direct marketing and other purposes. You may also prohibit the use of your personal data for direct marketing.

11.2 Right to review data

You have the right to review and obtain a copy of any data on you stored in Wellmonde’s website.

11.3 Right to rectify or remove data

Upon noticing incorrect personal data, the User must take the initiative to rectify, remove or add to the incorrect data in the register if possible or to inform Wellmonde of the personal data to be corrected as well as the correct personal data.

11.4 Right to data portability

If technically viable and required by law or by the authorities, the User has the right to copy, move or transport for their own use or to another data controller personal data that is mainly machine-readable, that they have provided to the data controller and that is processed through consent or an assignment.

11.5 Right to object and restrict data processing

The User has the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her. In the request, the User must specify the grounds for the objection. Wellmonde has the right to refuse the request based on reasons prescribed by the law.

The User has the right to restrict the processing of personal data concerning him or her as prescribed by law, for example, while the User waits for Wellmonde's response to a request to rectify or remove data

11.6 Right to lodge a complaint with a supervisory authority

The customer has the right to lodge a complaint with the supervisory authority if Wellmonde has not complied with appropriate data protection measures.

11.7 Exercise of rights related to personal data

For questions and information about the Privacy Policy and data subject's rights, please contact (controller's contact person). If necessary Wellmonde may ask the User to submit the request in writing. Wellmonde may, if necessary, take steps to confirm the identity of the Users before proceeding with any requests.

12. AUTOMATED DECISION-MAKING

We do not use automatic decision-making.

13. TECHNICAL AND ORGANISATIONAL SECURITY MEASURES

To protect your personal information, we apply necessary measures to safeguard the completeness, accuracy and privacy of the data collected by Wellmonde. We have implemented reasonable measures to protect the data from loss, misuse and changes.

Wellmonde uses Spring Security ACL to restrict access to Your personal data. Solution is developed in a way that SSL encryption can be used on a frontend and between all components.

It is important to note that if you click on any link on Wellmonde`s website that directs you from Wellmonde`s website to third party’s website, Wellmonde does not have control over such website and is not liable for the third party’s actions even if the connection exists between the websites. Before you proceed to a third-party website from Wellmonde`s website, we recommend you familiarize yourself with that particular website`s privacy policy before sharing any data.

14. OTHER

Wellmonde’s Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in search results or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organizations that advertise our services and that may use cookies and other technologies to offer other services.

Wellmonde’s may update their Privacy Policy from time to time. Wellmonde will not reduce your rights under this Privacy Policy without your explicit consent. In case updates are made to the Privacy Policy and/or the handling of any User data, corresponding notice will be posted on this Privacy Policy. The prior versions of this Privacy Policy in an archive for your review.

Your continued use of Wellmonde`s website indicates your consent to any changes to the Privacy Policy.

Contact us

The best way to reach us is through e-mail. Ask for more information if anything is unclear about the terms and conditions.

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