Privacy Policy

Effective Date 30th January 2024

Thanks for visiting Hairknowhow. Hairknowhow (“Hairknowhow”, “we”, “us” or “our”) respects your privacy. When it comes to your personal information, we believe in transparency, not surprises. That’s why we’ve set out here what personal information we collect, what we do with it and your choices and rights.

By using any of Hairknowhow services, you confirm you have agreed to the Terms and Conditions and read and understood this Privacy Policy and our Cookie Policy.

1. Some key terms

In our Privacy Policy, when we refer to “Users”, we mean our customers who use our services, including visitors to our sites. Any other capitalised terms not defined in this Privacy Policy have the meanings in our Terms and Conditions.

2. How does this Privacy Policy apply?

This Privacy Policy describes what we do with personal information that we collect and use for our own purposes, such as your account information and information about how you use and interact with our services, including information you submit to our customer support. This Privacy Policy does not apply to personal information of our employees or job applicants (except to the extent employees or job applicants are users).

We use cookies and similar technologies. Our Cookie Policy describes what we do in that regard.  

3. Personal information we collect

We collect various personal information regarding you or your device. This includes the following:

  • Information you provide to create an account, specifically email address, first name and last name. If you sign up for paid services, we receive a portion of your payment information from our payment processor (such as the last four digits, the country of issuance and the expiration date of the payment card), and we ask you to select your jurisdiction.

  • Your biological hair sample you sent us, or your client’s biological (if you are a hair clinic or trichologist representing your client).

  • Your marketing preferences.

  • The emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. Please be aware that information on public parts of our sites is available to others.

  • Information you share with us in connection with surveys, contests or promotions.

  • Information from your use of the services or users’ sites. This includes: IP addresses, preferences, web pages you visited prior to coming to our or our users’ sites, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the services and our users’ sites (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors).

  • Information we get from our partners to support our marketing initiatives, improve our services and better monitor, manage and measure our ad campaigns, such as details about when a partner of ours shows you one of our ads on or via its advertising platform.

  • Other information you submit to us directly or through third-party services if you use a third-party service to create an account (based on your privacy settings with such third-party service).

  • Information experimentally determined from biological samples that you submit to us.  This anonymised information may be used for research purposes with selected third parties or used to inform on advice given by ourselves to future customers.

4. How we collect personal information

We obtain personal information from various sources. We do this in three main ways:

  • You provide some of it directly (such as by registering for an account).

  • You submit a hair sample of us, after agreeing to our Terms and Conditions we experimentally analyse it yielding your (or your client’s - for hair clinics and trichologists) biometric hair data.

  • You may complete a survey or fill in online forms by submitting your personal information to us.

  • We record some of it automatically when you use our services (including with technologies like cookies). See our Cookie Policy for more information.

We’ve described this in more detail below.

a. Personal information you provide

When you use our services, we collect information from you in a number of ways.  For instance, we ask you to provide your name and email address to register and manage your account. We also maintain your marketing preferences and the emails and other communications that you send us or otherwise contribute, such as customer support inquiries, sample submissions or posts to our customer message boards or forums. You might also provide us with information in other ways, including by responding to surveys, submitting a form or participating in contests or similar promotions.

c. Information experimentally determined using our hair evaluation service.

Data is obtained using our in-house laboratory methods using your submitted hair sample.  The methods used and the data reported will depend on the level of service you subscribed to.

b. Personal information obtained from your use of our services

When you use our services, we collect information about your activity on and interaction with the services, such as your IP address(es), your device and browser type, the web page you visited before coming to our sites, what pages on our sites you visit and for how long and identifiers associated with your devices. If you’ve given us permission through your device settings, we may collect your location information in our mobile apps.

Some of this information is collected automatically using cookies and similar technologies when you use our services and our users’ sites. We let our users control what cookies and similar technologies are used through their sites (except those we need to use to properly provide the services, such as for performance or security related reasons). You can read more about our use of cookies in our Cookie Policy. Some of this information is similarly collected automatically through your browser or from your device.

c. Personal information obtained from other sources

If you sign up for paid services directly with us, we obtain limited information about your payment card from our payment processors, such as the last four digits, the country of issuance and the expiration date. Currently, our payment processor is Stripe and Paypal. Stripe and Paypal uses and processes your complete payment information in accordance with Stripe’s and Paypal’s Privacy Policy, respectively. Please see Google's privacy policy and Apple's Privacy Policy for information about how they use and process your payment information. 

5. How we use your personal information

We use the personal information we obtain about you for the following purposes:

  • Provision of the Services. Create and manage your account, provide personalised services, process payments and respond to your inquiries.

  • Your hair evaluation sample.  We determine your (or your client’s - for hair clinics and trichologists) biometric hair data using our analysis methods.  This hair data is then analysed to assess the health and other physical-chemical properties of the sample and is reported to you in line with the service you subscribed to.

  • Communicating with you. Communicate with you, including by sending you emails about your transactions, service-related announcements, and send you your hair analysis result report. Hair reports are encrypted and password-protected prior to sending to your nominated email address.

  • Surveys and contests. Administer surveys, contests and other promotions.

  • Promotion. Promote our services and send you tailored marketing communications about products, services, offers, programs and promotions of Hairknowhow and our partners and measure the success of those campaigns.

  • Advertising. Analyse your interactions with our services so we can tailor our advertising to what we think will interest you.

  • Customising the Services. Provide you with customised services. For example, we use your location information to determine your language preferences or display accurate date and time information.

  • Improving our Services. Analyse and learn about how the services are accessed and used, evaluate and improve our services (including by developing new products and services and managing our communications) and monitor and measure the effectiveness of our advertising. We usually do this based on anonymous, pseudonymised or aggregated information, which does not focus on you individually.

  • Security. Ensure the security and integrity of our services.

  • Third-party relationships. Manage our vendor and partner relationships.

  • Enforcement. Enforce our terms and conditions and other legal terms and policies.

  • Protection. Protect our and others’ interests, rights and property (e.g., to protect our users from abuse).

  • Complying with the law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests.

We process your personal information for the above purposes when:

  • Consent. You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time.  

  • Performance of a contract. We need your personal information to provide you with services and products requested by you, or to respond to your inquiries. In other words, so we can perform our contract with you or take steps at your request before entering into one. For example, we need your email address so you can sign into your Hairknowhow account and send you your results.

  • Legal obligation. We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.

  • Legitimate interests. We have a legitimate interest in using your personal information. In particular, we have a legitimate interest in the following cases:

    • To operate the Hairknowhow business and provide you with tailored advertising and communications to develop and promote our business.

    • To analyse and improve the safety and security of our services - we do this as it is necessary to pursue our legitimate interests in ensuring Hairknowhow is secure, such as by implementing and enhancing security measures and protections and protecting against fraud, spam and abuse.

    • To provide and improve the services, including any personalised services - we do this as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our Users on a sustained basis.

    • To anonymise and subsequently use anonymised information.

  • Protecting you and others. To protect your vital interests or those of others. 

  • Others’ legitimate interests. Where necessary for the purposes of a third party’s legitimate interests, such as our partners who have a legitimate interest in delivering tailored advertising to you and monitoring and measuring its effectiveness or our users who have a legitimate interest in having their sites function properly and securely and analysing the usage of their sites so they can understand trends and improve their services.  

6. How we share your personal information

We share personal information in the following ways:

  • Affiliates. We share personal information with our affiliates when it is reasonably necessary or desirable, such as to help provide services to you or analyse and improve the services they or we provide.

  • Business partners.  We may share personal information with business partners. For example, we may share your personal information when our services are integrated with their third-party services, but only when you have been informed or would otherwise expect such sharing.

  • Process payments. We transmit your personal information via an encrypted connection to our payment processor.  

  • Following the law or protecting rights and interests. We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests (such as enforcing our Terms and Conditions) or prevent fraud or abuse of Hairknowhow or our Users. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.

  • Advertising. We share personal information with third parties so they and we can provide you with tailored advertising and measure and monitor its effectiveness. For example, we may share your pseudonymised email address with a third-party social media platform on which we advertise to avoid serving Hairknowhow ads to people who already use Hairknowhow.

  • Business transfers. If we're involved in a reorganisation, merger, acquisition or sale of some or all of our assets, your personal information may be transferred as part of that deal or the negotiation of contemplated deals.  

7. Your rights and choices    

  • Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information.

  • You can access, update, change or delete personal information either directly in your account or by contacting us at Info@Hairknowhow.com to request the required changes. You can exercise your other rights (including deleting your account) by contacting us via your account at the same email address. Please note that we may need to verify your identity in connection with your requests, and such a verification process may, if you do not have access to your account, require you to provide us with additional information (e.g. government identification). Even if you have access to your account, we may request additional information if we believe it’s necessary to verify your identity. If we are unable to verify your identity or request, we may not, in accordance with applicable law, be able to fulfil your request.

  • You can also elect not to receive marketing communications by changing your preferences in your account or by following the unsubscribe instructions in such communications

  • Please note that, for technical reasons, there is likely to be a delay in deleting your personal information from our systems when you ask us to delete it. We also will retain personal information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies to the extent permitted under applicable law.

  • You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law. You also may have the right to lodge a complaint with a competent supervisory authority, subject to applicable law.

  • Our Cookie Policy explains how you can manage cookies and similar technologies.

  • Users should contact Info@Hairknowhow.com to exercise your rights with respect to any information we hold about you.

8. How we protect your (and your clients - for hair clinics and trichologists) personal information

  • While no service is completely secure, we are dedicated to keeping personal information safe. We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorised alteration, unauthorised disclosure or access, misuse and any other unlawful form of processing of the personal information in our possession. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities.

  • The sample (typically hair) you submit to us will be analysed, and once the results are reported to you will be destroyed within one week.

  • Hair analysis report and data are held on computers that are encrypted.

  • Hair reports prior to communication are encrypted and passworded so that only the authorised recipient may access the data contained within.

9. How we retain your personal information

  • We retain personal information regarding you or your use of the services for as long as your account is active or for as long as needed to provide you with the service. We also retain personal information for as long as necessary to achieve the purposes described in this Privacy Policy, for example, to comply with our legal obligations, to protect us in the event of disputes and to enforce our agreements and to protect our and others’ interests.  

  • The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymised, and other relevant criteria. For example, the period we keep your email address is connected to how long your account is active, while the period for which we keep a support message is based on how long has passed since the last submission in the thread.

  • Samples (typically hair) submitted to us will be analysed as per the service you subscribed to.  These physical samples will be held for no longer than one week after your hair report has been communicated to you.  Samples are destroyed prior to disposal.

  • As users may have a test once or come back to us after an account becomes inactive, we don’t immediately delete your personal information when you cancel all paid services. Instead, we keep your personal information for a reasonable period of time, so it will be there for you if you come back.

  • You may delete your account by contacting us at Info@Hairknowhow.com, and Hairknowhow will delete the personal information it holds about you (unless we need to retain it for the purposes set out in this Privacy Policy).

  • Please note that in the course of providing the services, we collect and maintain aggregated, anonymised or de-personalised information which we may retain indefinitely.

10. Data transfers

We rely upon a number of means to transfer personal information, which is subject to the European General Data Protection Regulation (“GDPR”) in accordance with Chapter V of the GDPR.  These include:

  • Privacy Shield. We transfer, in accordance with Article 45 of the GDPR, personal information to companies that have certified their compliance with the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks (each individually and jointly, the “Privacy Shield”).

  • Standard data protection clauses. We may, in accordance with Article 46 of the GDPR, transfer personal information to recipients that have entered into the European Commission approved contract for the transfer of personal data outside the European Economic Area.  

  • Your biological hair samples.  These will not be transferred to any third party.  They will be analysed on Hairknowhow property and then destroyed and disposed of within seven days of the hair evaluation analysis result being sent to you.

  • Sending or reporting your (or your client’s) hair test or analysis. Hair reports and test data is encrypted and passworded prior to transmission to your nominated email address. The necessary passwords used to access these reports are sent in a separate individual email to your nominated email address.

  • Other means. We may, in accordance with Articles 45 and 46 of the GDPR, transfer personal information to recipients that are in a country the European Commission or a European data protection supervisory authority has confirmed, by decision, offers an adequate level of data protection, pursuant to an approved certification mechanism or code of conduct, together with binding enforcement commitments from the recipient to apply the appropriate safeguards, including as regards data subjects’ rights, or to processors which have committed to comply with binding corporate rules.

11. Hair Clinic and Trichology Centre Client Data Protection

We understand the importance of privacy and data protection when it comes to the information provided by hair clinic clients. This section outlines our commitment to safeguarding client data and the measures we take to ensure its protection.

11.1. Collection and Use of Client Data

We do not collect personal data directly from hair clinic clients. Instead, we work exclusively with hair clinics and trichologists, utilising a unique personal identifier provided by them. This identifier serves as an internal reference within the clinic and HairKnowHow and is used solely for the purpose of hair evaluation analysis.

Your client’s biological hair samples.  These will not be transferred to any third party.  They will be analysed on Hairknowhow property and then destroyed and disposed of within seven days of the hair evaluation analysis result being sent to you.

11.2. Security of Hair Reports

To enhance data security, all hair reports generated by HairKnowHow are encrypted. These reports contain valuable insights and analysis results specific to the client's hair sample. We ensure that these reports are sent to the respective hair clinic in an encrypted format to prevent unauthorised access during transmission.

11.3. Data Storage and Access Controls

Client data, including unique personal identifiers and encrypted hair reports, are stored on secure servers with industry-standard encryption and access controls. We maintain strict access controls to ensure that only authorised personnel within HairKnowHow can access this data. Our employees and contractors are bound by strict confidentiality agreements to protect the privacy and confidentiality of the information.

11.4. Third-Party Disclosure

We do not disclose client data to any third parties unless required by law or with explicit consent from the hair clinic. We maintain a strict policy of confidentiality and prioritise the privacy of our clients' information.

11.5. Data Retention

We retain client data for a limited period necessary to provide our hair evaluation analysis services. Once the analysis is completed and the hair reports are delivered to the hair clinic, we retain the data for a period required by applicable laws and regulations. After the retention period has expired, we securely dispose of the client data to ensure its permanent deletion.

11.6. Data Breach Response

In the event of a data breach or unauthorised access to client data, we have implemented procedures to assess and mitigate the impact promptly. Our priority is to inform the affected hair clinic and take immediate steps to minimise any potential harm or unauthorised disclosure of client information.

12. Updates to this Privacy Policy

We’ll update this Privacy Policy from time to time to reflect changes in technology, law, our business operations, or any other reason we determine is necessary or appropriate. When we make changes, we’ll update the “Effective Date” at the top of the Privacy Policy and post it on our sites. If we make material changes to it or the ways we process personal information, we’ll notify you (by, for example, prominently posting a notice of the changes on our sites before they take effect or directly sending you a notification).

We encourage you to check back periodically to review this Privacy Policy for any changes since your last visit.  This will help ensure you better understand your relationship with us, including the ways we process your personal information.

13. How to contact us

If you have questions, comments or complaints about this Privacy Policy or our privacy practices or if you would like to exercise your rights and choices, please email us at Info@Hairknowhow.com, or contact us using our online form.

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