The data controller for your information is Hotspring Ventures Limited registered as a branch in Ireland (and trading as Treatwell IE) with registered address: 70 Sir John Rogerson’s Quay, Dublin 2, D02R296 ("Treatwell", "we", "our" or "us"). You can write to us at: 70 Sir John Rogerson’s Quay, Dublin 2, D02R296 or email us on: email@example.com or firstname.lastname@example.org.
What information do we collect?
When you visit and/or use our Platform or contact us, we may collect the following information:
- Personal Information that you choose to share with us when you register for an account, subscribe to emails, newsletters and alerts and which you provide to us when using our services, including information entered into our booking platform and included in your comments, reviews or survey responses. In the course of making a booking or submitting reviews, you might voluntarily provide us with sensitive personal data if relevant to the service that you are requesting or reviewing (relating to your health or ethnicity, for example).
- Personal Information that you share with us as part of an application for a job at Treatwell, submitted either directly on the Websites or indirectly, including but not limited to, via a recruitment agency, unsolicited application or third-party recruitment platform. In the course of making an application you may choose to voluntarily provide us with sensitive personal data relating to whether reasonable adjustments ought to be made for you in the application process or subsequently if an employment relationship is established. However, you must not share any sensitive personal data with us that would not be necessary for us to make reasonable adjustments for you, e.g. political opinions, religious beliefs or specific information on your state of health.
- Where you are utilising our online payment facility, we may store (via ourselves or our appointed payment processor) your credit and debit card details on a secure encrypted basis.
- If you choose to communicate with us (for example, through the Platform, live chat, email, telephone, SMS, or social media) we will record the fact that you have contacted us, the content of your and our communication, your contact details, and other unique identifiers including IP address and display name.
It is important that all the Personal Information you give us when you register as a user or otherwise when you use the Platform is correct and accurate. This includes, by way of example only, ensuring that we have your correct contact (including email) details at all times.
Protecting your personal information
The transmission of information via the internet is not completely secure. So, whilst we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our Platform. Any transmission is at your own risk. Once we have received your Personal Information we will use strict procedures and security features in relation to that data.
How do we use your personal information?
In general terms, we use Personal Information to provide you with the services and products you request, process payment, provide customer services, deliver our content and ads which we think may be of interest to you, for customer research, to send you marketing and promotional emails and to notify you about important changes to our Platform.
We also use your Personal Information for the following purposes:
- To fulfil a contract, or take steps linked to a contract. This is relevant where you request a service via Treatwell. This includes:
- Sending you information about your requested services (such as appointment reminders) by email, SMS and push notification
- Facilitating your bookings and taking payments
- Responding to your questions and concerns
- Administering your account
- As required by Treatwell to conduct our business and pursue our legitimate interests, in particular:
- To keep our Platform and systems secure and to prevent fraud, security incidents and other crime
- To verify compliance with our terms and conditions and for the establishment, exercise or defence of legal claims
- To notify you about new Treatwell services and special offers we think you will find valuable, for example via email and displaying advertising on third party websites such as Facebook (where consent is not required)
- To investigate and respond to any questions or complaints received from you or from others, about our Platform or our products or services
- To conduct internal research and analysis so that we can see how our Platform, products and services are being used and how our business is performing
- To conduct market research and consumer surveys
- To collate and publish reviews of products or services offered by our Partners, and use these for advertising campaigns
- To process applications for a position at Treatwell, whether submitted directly or indirectly, including to examine your suitability for the role, curriculum vitae, and professional skills, to schedule interviews and assessments, to contact referees and, if successful, to offer you a job and establish an employment relationship with you. Information which you provide will be held for a period of 12 months and may be referred to in the event you make future applications to work at Treatwell, unless you opt to delete this data which you may do so by following the link in the confirmation of application email that we sent you.
- Where you give us consent:
- To notify you about new Treatwell services and special offers we think you will find valuable, for example via email and displaying advertising on third party websites such as Facebook (where consent is required)
- To send you information about competitions and surveys and details of promotional offers of our Partners and about other selected third parties’ goods or services, for example those of health, beauty, leisure and lifestyle brands, by email and as push notifications via the App
- To pass your personal information to our Partners and other selected third parties, for example health, beauty, leisure and lifestyle brands, to enable them to send you information about their goods and services on their own behalf
- To use customer communications for training, record-keeping and quality control purposes. If you telephone our customer experience team, and consent by not opting out, your call may be recorded. You will be told if such a recording is being made and given the opportunity to opt-out of being recorded if you wish to do so and the means for doing so.
- On other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time
- For purposes which are required by law:
- To respond to requests by government or law enforcement authorities conducting an investigation
- To meet legal, regulatory and compliance requirements
Legitimate Interests Balancing Tests
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us at email@example.com.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
- If you would like to unsubscribe from receiving communications which Treatwell sends you, you can do so by clicking the “unsubscribe” button at the bottom of email communications which we send you or alternatively by contacting us at firstname.lastname@example.org. In the case of email marketing please allow 48 business hours for your email address to be removed from our system.
- If you would like to unsubscribe from receiving communications which are sent by Partners and other third parties, please contact the Partner or third party directly. In the case of our Partners, if you need our assistance with this, we will be happy to do what we can to help you.
- If you would like to no longer receive push notifications via the App, you can do so by revoking push notification permission for the Apps in your phone’s operating system settings.
Please note that where you have opted out of receiving our email marketing communications via the methods described above, you may still see our non-targeted adverts whilst you are online, if your interests settings on Facebook are aligned to an audience segment (pre-defined by Facebook) which our business is also associated with. We do not control whether these ads are displayed to you.
Sharing personal information with third parties
We treat the security and method of processing your Personal Information very seriously, and we will never sell your Personal Information under any circumstances.
However, we may disclose your Personal Information to selected third parties, including in the following situations:
- Hotspring Ventures Limited: Fairfax House, 15 Fulwood Place, London, WC1V 6HU, email@example.com
- Treatwell IE, branch of Hotspring Ventures Limited: Fairfax House, 15 Fulwood Place, London, WC1V 6HU, firstname.lastname@example.org
- Treatwell LT UAB: J. Basanavičiaus g. 15, 03108 Vilnius, Lithuania, email@example.com
- Treatwell Spain s.l.: Carrer de Balmes, 7, Planta 3, 08007 Barcelona, Spain, firstname.lastname@example.org
- Treatwell IT s.r.l.: Via Aldo Manuzio, 17, 20124, Milano, Italy, email@example.com
- Treatwell FR: 52 rue de la Chaussée d’Antin – 75009 Paris, France, firstname.lastname@example.org
- Treatwell BNL B.V.: Nieuwezijds Voorburgwal 120-126, 1012 SH Amsterdam, Netherlands, email@example.com
- Treatwell DACH GmbH: Greifswalder Str. 212, 10405 Berlin, Germany, firstname.lastname@example.org
- Treatwell DACH GmbH, Zweigniederlassung Zürich: Haggenholzstrasse 83b, 8050 Zürich, email@example.com
- Treatwell DACH GmbH, Zweigniederlassung Wien: Badhausgasse 18-20, Top 1-3, Lerchenfelderstraße 95-97, 1070 Wien, firstname.lastname@example.org
- If you place an order or otherwise engage with Treatwell through a website or app powered on behalf of a third party, then your contact details and details of your order will be passed on to the relevant third party, for example lastminute.com when you make a booking via spa.lastminute.com. If you give a third party (such as lastminute.com) the relevant consents (which Treatwell collects on behalf of third parties), they may also send you marketing communications.
- To third party service providers that perform functions on our behalf in relation to the Platform or otherwise in connection with the running of our business, recruiting candidates and for the provision of Treatwell's services (for example, processing credit card payments, website hosting, conducting surveys and market research, providing social media analysis, providing marketing email services, data analysis tools and to manage customer services communications including telephone calls and live chat).
- To our Partners with whom you book services whether via our Website or Apps, where we act as commercial booking agent, or directly with the Partner via our Partner Platform or Widgets, where we act solely as a technology provider. Your information is shared with Partners in order that:
- bookings can be facilitated and, if necessary, contact made in advance of your appointment;
- if you have opted in to receiving marketing emails from Partners with which you book, these emails can be sent to you containing news and special offers; and
- they can improve the services they offer to their customers and business operations by providing statistical data regarding customers, both on an aggregated basis and on an individual level.
- To third party brands with which we collaborate on products, services, competitions and campaigns
- To third party salon software providers used by our Partners to ensure that those third party software solutions and Connect each display real-time availability to customers
- To other third parties, for the purpose of facilitating our business and improving our products, content, services or advertising including, by way of example only, sending email communications or publishing reviews of our or our Partners' products and services
- If we buy, sell or transfer any business or assets or if go into insolvency, bankruptcy or receivership. If this should happen, we may need to disclose your Personal Information to the seller or buyer of such business or assets, as appropriate
- If we are under a duty to disclose or share your Personal Data to comply with any legal obligation or in order to enforce or apply our terms and conditions and other agreements or protect the rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction
- To government authorities, and to other third parties as required or permitted by law, including but not limited to in response to court orders. We also may disclose user information when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of our Platform, or anyone else that could be harmed by such activities.
Please note: by posting any Personal Information in any publicly accessible area of our Platform (such as review sections), such information may be collected by third parties over which we have no control. We are not responsible for the use of such information by such third parties.
Please therefore exercise all due care and consideration before disclosing any Personal Information that will be disclosed on public areas. You should also avoid disclosing on public areas any Personal Information that may be used to identify you (such as your name, age, home or work address or name of your employer).
Your rights in relation to your personal information
In relation to the personal information we hold about you, you may be entitled to ask us:
- For a copy of your personal information
- To correct, erase or restrict the processing of your personal information
- To obtain personal data which you provide to us for a contract or with your consent in a structured, machine readable format and to ask us to transfer this information to another organisation
- To object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
In the first instance you may be able to view or change the information you have provided us with by logging in to your online account.
Your rights in relation to your personal information are limited in some situations. For example, if fulfilling your request would reveal personal data about another person or if we have a legal requirement or a compelling legitimate ground we may continue to process Personal Information which you have asked us to delete. You also may have the right to make a complaint if you feel your personal information has been mishandled. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant supervisory authority.
If you wish to exercise any of the above rights, please contact us at email@example.com. Please note, however, that no financial information will be provided without verification.
What about other websites linked to our Platform?
We are not responsible for the practices employed by websites linked to or from our Platform nor the information or content contained therein. Often links to other websites are provided solely as pointers to information on topics that may be useful to the users of our Platform.
Social Media and User Generated Content
Some of our Platforms allow users to submit their own content. Please remember that any content submitted to one of our Platforms can be viewed by the public, and you should be cautious about providing certain personal information e.g. financial information or address details via these Platforms. We are not responsible for any actions taken by other individuals if you post personal information on one of our social media platforms, e.g. Facebook or Instagram. Please also refer to the respective privacy & cookie policies of the social media platforms you are using.
If we change our privacy policies and procedures, we will post those changes on our Platform to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it.
Where we store your personal data
The data that we collect from you may be transferred to and stored at a destination outside the UK and European Economic Area (EEA), including in the US and Israel, including for the purposes of processing that data by selected third parties, in order to facilitate Treatwell's business. Countries outside the EEA may not have laws which provide the same level of protection to your personal data as laws within the EEA. Where this is the case personal data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification, a vendor's Processor Binding Corporate Rules, or another adequacy mechanism established under applicable data protection law. A copy of the relevant mechanism can be provided for your review on request to firstname.lastname@example.org.
- where you apply for a position at Treatwell, whether directly or indirectly, information which you provide will be held for a period of 12 months and may be referred to should you make future applications to work at Treatwell, unless you opt to delete this data which you may do so by following the link in the confirmation of application email that we sent you;
- where you contact us via live chat on the Platform, we usually retain customer live chat data for up to 60 days after the end of the session; and
- where you contact us via telephone and do not opt-out, we shall retain call recordings for up 90 days from the date of the call.
Our policy on Cookies
Please see the table below for a live breakdown of the Cookies that are used on our Platform:
The third party companies that we use for targeting and advertising purposes have their own privacy policies which you should read in detail.