VINE HAIR PRIVACY POLICY
Who we are
Vine Hair is a Limited Company with an address of 1 Castle Street Tunbridge Wells Kent TN1 1XJ, (“Vine Hair”, “we” or “us”).
Our Contact details
Vine Hair is the data controller responsible for your personal data. If you have any questions, comments or requests regarding this privacy notice or our data protection practices, please contact us by email at admin@vinehair.co.uk
Purpose of this privacy notice
This privacy notice aims to give you information on how Vine Hair collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a service, or sign up to our Masterclass, or contact us. It also explains your privacy rights and how the law protects you. Please read the following carefully to ensure that you fully understand how and why we are using your personal data.
This website is not intended for children and we do not knowingly collect data relating to children.
If you are under 16 years of age, you should always ask your parent or guardian before buying products from as well as responding to anything on and asking us to send anything to you or another young person on our website.
Our commitment
We are committed to protecting and respecting your privacy and we process your personal data in accordance with the overarching principles and requirements set out in the UK General Data Protection Regulation and the Data Protection Act 2018 (‘Data Protection Law’). What this means is that we process your data in a way that is:
Lawful, fair and transparent;
Compatible with the purposes that we have told you about;
Adequate and necessary, we only use the data we need to use for the reason we told you;
Accurate and up to date;
Not excessive, we only keep your data for as long as we need it; and
Secure and protected.
Third-party links
This website does contain links to and from the websites of payment portals, online booking systems, online learning platforms, our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
To attend our online courses, we will issue you with a link to a third party website or application (such as Kajabi or Zoom) where we deliver the course content to you. To access the courses, you will be asked to enter some personal data into the third party platform, including your name and email address. To pay for our online courses, you will be redirected to a third party website or application (such as Stripe) where you will make payment. The third party platforms we use operate their own terms and conditions and privacy notices and we do not accept responsibility or liability for the way these parties use your personal data.
Personal data we may collect from you
Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data: your name and title.
Contact Data: your address, email address and telephone numbers, social media handle.
Usage Data: information about how you use our services and website.
Technical Data: your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in type, operating system, and other technology on the devices you use to access our website.
Transaction Data: includes details about payments to and from you and other details of services you have purchased from us.
Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific service feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How your personal data is collected?
We may request that you provide us with personal data when you:
Sign up to our Masterclass;
Become a customer of Vine Hair
Purchase our services;
Complete a form on our website;
Sign up to our marketing;
Contact us by phone, email, social media or otherwise;
To manage your relationship with us;
To recommend products or services which may be of interest to you;
Submit feedback to us on our website.
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Most browsers accept cookies automatically, but you can visit the ‘options’ or ‘preferences’ menu on your browser to change these settings. You have the option to accept cookies, to be notified when a cookie is issued or refuse cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Please see our cookie policy here for further details.
How your personal data is used
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
We have set out a table in Annex A to this notice, which provides a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
How long do we keep your data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. Generally, we will keep personal data which we collect for up to two years after you cease using our services, for any of the purposes mentioned above. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
Marketing
With your consent we may:
send you information about special offers, products and services which we think may interest you; and
use Facebook to market to you by creating custom ads for you by uploading your name and email address to Facebook. Your name and email address matches to your profile and Facebook provides us tools on its platform to create a group of these matches which then allows us to create ads for the purposes of showing you direct marketing.
We may ask permission to share your information with third parties affiliated with us so they can send information about their special offers, products and services. You can ask us or third parties to stop sending you marketing messages at any time following the opt-out links on any marketing message sent to you or by contacting Vine Hair
How we share your personal data
We may share your personal data with the parties set out below for the purposes set out in the table in Annex A:
External third parties that provide us with services related to our IT systems and marketing, professional advisers that provide us with legal, insurance and accountancy services and regulatory bodies, where we have a legal obligation to do so;
Specific third parties such as:
Stripe to process payment of our services. Stripe’s privacy notice can be accessed here.
Kajabi, we use to host/gate our private course content behind a pay wall. Its privacy notice can be accessed here.
Calendly to host the online booking system to arrange discussions prior to you signing up for our services. Its privacy notice can be accessed here.
Zoom to host question and answer sessions. Its privacy notice can be accessed here.
Drip for marketing purposes. Its privacy notice can be accessed here.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International Transfers
Some of our external third parties are based outside the UK, in the US for example, so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries outside the UK that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. This includes:
right to request access to your personal information – you can request a copy of the personal information we hold on you;
right to request correction of your personal information – if any personal information we hold on you is incorrect, you can request to have it corrected;
right to request erasure of your personal information – you can ask us to delete your personal information in certain circumstances;
right to object to processing or restrict processing of your personal information – you may object to our processing of your personal data in certain circumstances;
right to request the transfer of your personal information – to provide you, or a third party you have chosen, with your personal information; and
right to withdraw consent – where we process your data on the basis of consent, you can notify us that you want to withdraw consent any time.
If you wish to exercise any of the rights set out above, please contact us at Vine Hair.
If you have any data protection complaints, you may contact the Information Commissioner’s Office (ICO) by post at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Email: casework@ico.org.uk Telephone: 0303 123 1113
We’d like to try and help with any concerns you may have before you contact the ICO, so please get in touch with ben@contentkweens.com in the first instance.
Changes to the privacy notice and your duty to inform us of changes
Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. We keep our privacy notice under regular review. Please check back frequently to see any updates or changes to our privacy notice.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Annex A – Processing Purposes
This table format described the ways we may use your personal data when you buy products from our website, and the legal bases we rely on to do so.
Purpose
Type of personal data
Legal basis for processing
When you agree to become a customer of Vine Hair
Identity and Contact Data
Performance of a contract with you
When you attend our courses
Identity, Contact, Transaction, Technical Data
Performance of a contract with you
To manage our relationship with you by responding to your enquiries and notifying you of changes to our terms or privacy notice
Identity, Usage, and Contact Data
Performance of a contract with you
Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To contact you for the purposes of research, feedback and surveys
Identity, and Contact Data
Performance of a contract with you
Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Contact, Technical, and Usage Data
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)
Consent (to set cookies)
Necessary to comply with a legal obligation
To administer our services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
Identity, Contact, and Technical Data
Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Identity Contact, Usage, Technical, Marketing and Communications Data
Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences
Technical and Usage Data
Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products or services that may be of interest to you through our marketing emails
Identity Contact, Technical, Marketing and Communications Data
Consent
Necessary for our legitimate interests (to develop our services and grow our business)
To make create custom ads on Facebook to you tell you about our products or services that may be of interest to you
Identity Contact, Technical, Marketing and Communications Data
Consent