This is the Privacy (and Cookies) Notice ("Notice") for the website www.fresha.com , and all Fresha affiliate sites ("Sites"), or our applications ("Apps") (together "Services").
What information do we collect & how do we use it?
This Privacy Notice will apply to you if:
- you visit and browse our Sites and Apps.
- You order products from or book appointments with our Partners through us (we'll refer to you as a "Client").
- you are self-employed and/or you work for a business on the Fresha platform (we'll refer to you and/or the business as a "Partner").
We will only use the information we collect about you if there is a reason for doing so, and if that reason is permitted under data protection law. We say what these reasons usually are in each section below, and we explain each one under 'What do each of these legal reasons mean?'.
If you visit our services
We use your information to provide you with our Services. If you visit any of our Services, whether you're just browsing or you have an account, we will automatically collect information from you each time you use our Sites. This includes technical information, information about your visit and (if you opt-in) location data:
Technical information may include the phone number, Internet Protocol (IP) address, login information, browser type and version, browser plug-in types and versions, device IDs, social log-in ID/email address, time zone setting, operating system and platform, hardware version, device settings (e.g. language and time zone), file & software names and types (associated with your device and/or the Services), battery & signal strength, information relating to your mobile operator or Internet Service Provider (ISP).
Information about your visit
Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time), pages and services you viewed or searched for, demographic information (including age and gender), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), traceable campaign links (e.g. in emails, or via tracking URLs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team and our social media accounts.
Location data includes country location (based on your full or partial IP address and/or Google Analytics information) which we use to provide location services (if you ask or permit us to), so that we can deliver content, advertising or other services that are dependent on knowing where you are, like checking for fraudulent transactions.
Location data may be collected in combination with device ID, so we can recognise your mobile browser or device when you return to the Service.
Delivery of location services will involve us checking any of the following:
- the coordinates (latitude/longitude) of your location,
- your current country or region, by referencing your current IP address against public sources, and/or
- your Identifier for Advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device identifier.
You can opt-in and out of location sharing by changing your device settings
We use this automatically collected information to
- understand how individuals use our Site, and how we can improve it;
- ensure content from our site is presented in the most effective manner for you and for your devices; and
- provide you with the information, products and services that you request from us or we think you may be interested in.
If you contact or engage with us
If you contact or engage with us, we will collect your contact information, and the other communications information you provide.
Contact information includes basic contact information you provide:
- email address,
and anything else you include, for example:
- first and last name,
- phone number(s),
- social media handle (for example, if you engage with us on social media).
Communications information includes your correspondence with us, for example if you get in touch with our Customer Service team about an order or booking or to report a problem with our Site. This includes:
- texts, in-app messaging & other digital messaging,
- any in-person conversations you have with us.
We use this contact and communications information to
- Contact you if you have asked us to do, including to respond to your queries, troubleshoot problems, and help with any issues you may have with our Services.
- Provide you with information you might request about our Services.
- Put you in touch with Partners you ask us to share your information with.
If you use our services to book an appointment
When you create a Fresha account using any of our Services, we may collect your:
- first and last name;
- date of birth
- email address;
- mobile phone number(s),
- your photo, if uploaded (optional).
- If you choose to use your Google, Facebook, or Apple account to sign into Fresha, we will get an access token that enables this sign-in process (granting us access to your first and last name, email, user ID and (apart from Apple) your profile photo).
- We assign unique user IDs or other account-level IDs to your Fresha account.
As you use your account, we may collect information about your:
- purchase history, including product orders or appointment bookings, or voucher purchase and use;
- favourites (e.g. your favourite salon or gym);
- account settings;
- social login information;
- securely saved payment methods.
- We may also collect information, if you provide it, about your preferences, referrals, or how you found out about our Services, or other user generated content (e.g. profile photo, reviews).
We use this account and related information to manage your account with us, including to
- maintain your Fresha account;
- provide customer support;
- enable you to contact, order from and make bookings with our Partners;
- enable you to make and pay for orders and bookings with your account;
- if a Partner offers home services and you select the option, to enable you to book appointments at the address you provide;
- provide you with a personalised experience, including recommending features, services, products and Partners we think you may be interested in.
You may provide Partners with consultation, order and booking information (like date and time of your appointment). Partners may also ask you, via consultation forms on our Services, for health information (for example if you are pregnant) or other sensitive information (called "special category data").
You may opt-in to receive marketing from a Partner. Partners may also upload their own customer information to Fresha, including to use our Services to send marketing (Fresha will not use this uploaded information for its own purposes). Partners are responsible for their own marketing.
The Partner is the data controller for this information. If you have any questions, please contact the relevant Partner.
If you order any products from a Partner's shop
When you order any products from a Partner's shop, we may collect your:
- order details and purchase records, including any related correspondence via our Services;
- cancellation, return and refund records;
- securely saved payment methods; and
- your product reviews or ratings.
We use your account and order information to enable our Partners to fulfil and manage your orders, including to
- enable you to contact and purchase products from our Partners, including making payments,
- share your contact and order information with the Partner you ordered from, so the Partner can fulfil and manage your order (including processing any cancellations, returns or refunds), and communicate with you about your order.
- store your order, cancellation, return and refund records.
If you work for a Partner
If you work for our Partner (e.g. as an employee, contractor, or worker), we may collect contact and company information from you:
Contact information may include:
- first and last name,
- role title,
- company name,
- email address,
- contact number,
- log-in details,
- KYC and ID verification results (we do not keep any underlying documents).
Company information may include:
- company address,
- business type (e.g. salon, spa, gym),
- consultation form content,
- historical and future appointments,
- point of sale data,
- payment processing data (we don't see this, only our payment processors do),
- reporting and analytics,
- Client data and promotions;
- pictures and marketing materials.
We also process other information on behalf of your company that is not personal data (for example, financial data and product inventory).
We use this contact and company information to manage the Partner's account with us, including to
- maintain the Partner's account,
- provide Partner customer support, including technical support for our suite of business tools,
- enable the Partner to use our suite of business tools, including managing staff and appointment scheduling,
- enable the Partner to make transactions and manage payments,
- enable the Partner to manage marketing promotions via the Services,
- enable the Partner to list on the Fresha's marketplace
- enable the Partner to manage inventory and use point of sale devices,
- may contact Partner staff to enable them to create a Partner-specific account with appropriate authorisations, and to manage those accounts.
The Partner can access and manage your Fresha account details.
Partners may also control what information Clients can see about the Partner, including order or booking information, staff names and certain profile information, offers, ratings and reviews (which may talk about staff members), prices and discounts, appointment availability, and related data.
The Partner you work for is the data controller for this information. If you have any questions, please contact the Partner you work for.
If we send you offers, updates or other marketing material from us
We may collect contact information (as explained above), like your name and email address.
We may also collect marketing preferences, which are our records of what information you would or would not like to receive from us, and if you have opted out of any direct marketing.
We use this contact and marketing preference information to
- send you offers, updates, promotions, newsletter(s), insights and other marketing material.
- send you with a personalised marketing, including offers, features, services, products and Partners we think you may be interested in.
- If you work for a company we are interested in partnering with, we may contact you about our Services and opportunities with Fresha.
- Contact you to ask for feedback, including through surveys and other marketing research.
You can opt-out of further marketing at any time by selecting the “unsubscribe” link at the end of all our promotional updates.
What do each of these legal reasons mean?
We must have a relevant legal justification, called a 'lawful basis' for each way in which we use your personal information.
Lawful bases may include consent, a contract with you (as a data subject), compliance with our legal obligations and our specified legitimate interests.
We'll use your personal information to send you promotional or marketing content (for example, our insight updates or newsletters), if you have given us consent to us doing so, where required by law. We may also send direct marketing based on our legitimate interests (see below).
You can opt-out of further marketing at any time by selecting the “unsubscribe” link at the end of all our promotional updates and marketing to you.
We also rely on consent for some of the cookies we use (see our Cookies Notice for more detail).
We may need to process any of your personal information to comply with our legal obligations, including under applicable UK law, and/or any court orders. This may include compliance with know-your-client and anti-money laundering rules.
We may process your personal information if it is necessary for our legitimate interests or the legitimate interests of a third party, provided those interests are not outweighed by your rights and interests.
Our legitimate interests include:
- Administering, improving and expanding our Site and services
- Keeping our records updated.
- Gaining insights on how you use our Services.
- Gaining your feedback and reviews,
- Delivering, developing and improving our Services.
- Enhancing, customising or modifying our Services and communications.
- Implementing and improving our security measures
- Growing our business and informing our marketing strategy.
- Marketing and promoting our Services to a company you work for or provide services to.
- measuring or understanding the effectiveness of advertising we serve to you and others and delivering relevant advertising to you (including when you visit other websites).
- Fulfilling agreements with another organisation
- Complying with or enforcing any agreement Fresha has (or that you may have, or example any extra Partner-specific terms) with a Partner you have purchased goods or services from as a Client.
- Complying with or enforcing any agreement we may have with a company you work for or provide services to (for example, if you work at a Partner).
- Fulfilling agreements with another organisation
In each case, these legitimate interests are only valid if they are not outweighed by your rights and interests. If you would like further information about how we assess our legitimate interests, please contact us at email@example.com.
We also use different types of cookies on our Site – we explain this in the Cookies Notice.
Who do we share your information with?
If you are a Client
We will share your information with our Partners if you have asked us to (for example, if you want to connect with, order from or make a booking with one of our Partners). We may share your contact and account information, and they will receive any other information you provide through Fresha (for example, completing a Partner's consultation form). Partners may use this information to manage your communications, orders and bookings with them.
If you leave a public review for a Partner (or any of their products in their shop on our Services), your rating, review, review date, and first name and last initial will be published on Fresha. Other Fresha users and members of the public may be able to see your reviews. Reviews may be published or syndicated on third party websites. Public reviews will survive the termination or expiry of the Fresha Terms of service.
If you work for a Partner
Fresha users may rate the Partner you work at or for, and may rate you as an individual. Your individual ratings may be shared with the relevant Partner, and may be publicly available on our Services.
We may publish limited Partner information (including individual and business public reviews and ratings) to other websites, for example so it can be included in search results or advertising (including online and offline advertising and promotional media, including, but not limited to Google, Google AdWords, Facebook Ads, Twitter, email distribution lists, and third-party business partners and affiliates).
If Fresha processes your information as a Client, Partner staff, or otherwise
We may also share your information with:
- any member of our company group, which means our ultimate holding company and its subsidiaries, and/or our subsidiaries who may support our processing of personal information under this Notice.
- our service providers, organisations who process your personal data on our behalf and in accordance with our instructions and the data protection law.
- This includes supporting the services we offer through the Site, in particular those providing website and data hosting services, distributing communications we send, supporting or updating marketing lists, customer support, facilitating feedback on our services, digital invoicing and payment processing providers who provide secure payment processing services, and providing IT support services from time to time.
- These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your information to the extent necessary to perform their support functions.
- if you create a Partner Account with us by using a Referral Link the Partner who the Referral Link relates to may view the progression of your Partner Account
- if we run surveys, competitions, promotional campaigns, offers or other occasional activities and you opt-in, we may share certain information with our commercial partners (for example, if you chose to enter into a prize draw we run with a third party). We will provide more detailed privacy information at the time.
- our auditors, legal advisers and other professional advisers;
- if we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer.
- if required to do so by court order or if we are under a duty to disclose your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation. This includes exchanging information with law enforcement agencies, regulators, or other similar government bodies.
Where do we store your information?
Fresha operates globally, including in the United States, Canada, United Kingdom, Australia, the United Arab Emirates, Netherlands and other countries in the European Economic Area ("EEA"). We generally don't share personal data between group companies.
We may transfer your personal information outside the UK / EEA:
- in order to store it;
- in order to enable us to provide our Services to you;
- in order to facilitate the operation of our businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights; and
- where we are legally required to do so.
We will put legal protections in place to safeguard personal data transfers in compliance with data protection laws.
We may transfer your personal information outside the UK / EEA, including to the key organisations listed here.
We update our partners and service providers as we grow, and will update this Notice regularly. For more information about how we currently transfer and protect data, please contact firstname.lastname@example.org.
How do we protect your information?
All information you provide to us is securely stored. Our website uses secure end-to-end encryption to protect your information. All connections into our platform are secured using industry standard security and encryption.
All data we capture is stored in secured databases and data storage systems with strict access limitations. All data access requests are logged and monitored in accordance with any threat detection policies.
Unfortunately, the transmission of information via the internet is not completely secure. We do our best to protect your personal information, but we cannot guarantee the security of your data transmitted to us – even if there is a special notice that a particular transmission (for example, credit card information) is encrypted. Any transmission is at your own risk. Once we have received your information, we use strict procedures and security features to try to prevent unauthorised access.
Payments made on our Services are made through our payment gateway provider, Adyen N.V., ("Adyen") (or, if you are in the UAE, Checkout MENA FFZ LLC ("Checkout")). You will be providing credit or debit card information directly to Adyen (or Checkout), which operates a secure server to process payment details, encrypting your credit/debit card information and authorising payment. Fresha can view pseudonymized cardholder and card details. In addition, Fresha stores the following card information:
- card brand,
- card holder name,
- card's last four digits,
- card expiry month and expiry year.
Fresha may, from time to time, contain links to external sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies. Fresha does not accept any responsibility or liability for these policies or any content on external sites and does not necessarily endorse the views expressed within them. Fresha has no control over the availability of any of these websites. Please check each site's policies before you submit any personal information to these websites.
How long is your information kept for?
We will generally process personal information:
- for as long as it is necessary for the purpose(s) for which it was originally collected (for example, holding it on behalf of a Partner, or for as long as you have an account with us), and
- for up to six years after that to identify any issues and resolve any legal proceedings.
We may retain your personal data for a longer period in the event of a complaint, if we reasonably believe there is a prospect of legal proceedings, or we are aware of pending or ongoing legal proceedings. In some circumstances, we may keep data longer if applicable law says we have to.
If you have opted to receive insights, newsletters, or other promotional material, but later decide to opt out from receiving these updates, or object to any other processing of your personal information, we may keep a record of your opt-out or objection so we can respect your preferences.
We may keep aggregated, anonymised or pseudonymized data – for example, for reporting and analytics – for longer periods.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you and you cannot be re-identified). This anonymised data (for example, aggregated statistics) is no longer personal data, and we may keep and use this anonymised information indefinitely without further notice to you.
We use this to help us provide, develop and improve our services, including to:
- better understand how people use our Services,
- provide our Partners and Clients with information about our Services, including user statistics (e.g. total numbers, broad demographics statistics), and
- develop useful insights and improvements to the Services.
What rights do you have with your personal information?
In certain circumstances, you have the following rights:
- to be provided with a copy of your personal information held by us;
- to request the correction or deletion of your personal information held by us;
- to request that we restrict the processing of your personal information (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your personal information, including the right to object to marketing;
- to request that your provided personal data be moved to a third party, and
- to withdraw consent.
If you wish to exercise any of these rights in relation to the personal information we hold about you, you can contact us at email@example.com. If you have any concerns, you have the right to lodge a complaint with a data protection supervisory authority.
The Information Commissioner's Office (ICO) is the supervisory authority in the UK and can provide further information about your rights, an organisation's obligation in relation to your personal information, as well as deal with any complaints that you may have. You can visit their website at www.ico.org.uk.
If you are outside the UK, you can find your local data protection authority here.
Updating this Privacy notice
This Notice was last updated on 11 Feb 2022.
We may update this Notice from time to time and will post any changes on this page.
If we make any substantive changes, we will notify you through email, or website pop-ups within our Site.
A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser or exit one of our Sites. Others are used to remember you when you return to one of our Sites and will last for longer.