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TREATWELL’S TERMS AND POLICIES

Please read these Terms and Policies carefully before you start to use our Website or our Apps and before booking any third party goods or services through our Website or our Apps. We recommend that you print a copy of these for future reference.

By using our Website or our Apps, you confirm that you accept these Terms and Policies and that you agree to comply with them regardless of whether you choose to register with us. If you do not agree to these Terms and Policies, you must not use our Website or our Apps in any way.

1. Welcome to our website, www.treatwell.ie/ ("Website") and to the Treatwell Customer mobile application and the Treatwell Connect (salon diary and management tool) mobile application (the “Apps”). The Website and our Apps are provided by Treatwell IE, a branch registered in Ireland under number 567619 being a branch of Treatwell Limited, a company registered in England under company number 06457679 and whose registered office is at Fairfax House, 15 Fulwood Place, London, WC1V 6HU, with VAT registration number 928047219 ("Treatwell", "us", "we" or "our" for short). "You" and "your" means you as the user of our Website or our App.
2. The Website and our Apps have two main functions:
   1. aggregating of information and providing a centralized booking point for selected third party goods and services providers who wish to offer their goods and services for sale via our Website and our Apps ("Partners"); and
   2. provision of general information relating to health and wellbeing.
3. We have set out the terms under which we are providing you with access to our Website and our Apps and any products or services we offer from our Website or our Apps. These include the terms and conditions that govern:
   1. your rights to use and link to our Website and our Apps (our "Website & App Terms of Use");
   2. how we will use and protect information about you (our "Privacy & Cookies Policy");
   3. our booking terms and conditions in relation to the third party products or services we offer from the Website or our Customer mobile application (our "Booking Terms and Conditions"); and
   4. your obligations when uploading comments or other contributions and content to our Website or our Apps (our "User Generated Content Policy"),
      (together or individually these may be referred to as our "Terms and Policies").
4. Please note that the Terms and Policies do not govern the relationship as between Treatwell and our Partners. If you are an existing Partner, please check the “Partner Terms of Business” provided to you upon sign up. If you are not yet a Partner but would like to apply to Treatwell to become one of our Partners, please see www.treatwell.ie/business/.
5. If you enter any prize competitions or other promotions on the Website or our Apps, separate terms and conditions may also apply in addition to our Terms and Policies. In the event of a conflict between any additional terms and conditions and our Terms and Policies, such additional terms shall prevail to the extent of the conflict.
6. We may change our Terms and Policies from time to time, in which case up to date versions of such Terms and Policies will be available via the Website and our Apps. You should check these Terms and Policies regularly to ensure that you are happy with any changes. You will be deemed to have accepted any changes to the Terms and Policies after you have been notified of the changes on our Website or our Apps and/ or if you continue to access or use the Website or our Apps, where the updated Terms and Policies will be available for you to view.

WEBSITE & APP TERMS OF USE

Please read these Website & App Terms of Use carefully before you start to use our Website or our Apps, as they apply to your use of our Website and our Apps. We recommend that you print a copy of these for future reference.

These Website & App Terms of Use refer to the following additional terms which also apply to your use of our Website and our Apps:

• Our Privacy and Cookie Policy; and
• Our User Generated Content Policy.

By using our Website or our Apps, you confirm that you accept these Website & App Terms of Use and that you agree to comply with them. If you do not agree to these Website & App Terms of Use, you must not use our Website or our Apps.

Please note: these Website & App Terms of Use only cover your use of our Website and our Apps, they DO NOT apply to the third party goods and services which are available for booking on our Website or our Customer mobile application. Please see our Booking Terms and Conditions for the terms and conditions which apply when you make any bookings or purchase any vouchers from our Website or our Customer mobile application.

Within these Website & App Terms of Use, the phrase “Terms and Policies” refers to any or all of the following policies: our Privacy and Cookie Policy, our User Generated Content Policy, these Website Terms and Conditions and our Booking Terms and Conditions.

1. Use of the Website and our Apps
   1. These Website & App Terms of Use set out how you may use our Website and our Apps. By accessing the Website or our Apps, you agree to these Website & App Terms of Use. These Website & App Terms of Use apply to whatever method you have used to access the Website or our Apps, including but not limited to the internet, digital television services and mobile phone.
   2. If you do not agree to these Website & App Terms of Use, you should not use the Website or our Apps. You should read all of the Website & App Terms of Use prior to using the Website or our Apps.
2. Accessing our Website and our Apps
   1. Access to our Website and our Apps is permitted on a temporary basis. We reserve the right to withdraw or amend our Website or our Apps (and any products or services offered on them) without notice. We will not be liable if for any reason our Website, our Apps or any part of it or them is unavailable at any time or for any period.
   2. We update our Website and our Apps from time to time and so may change the content at any time without notice to you. We reserve the right to withdraw, vary or suspend the Website or our Apps (or any part of them) at any time without notice.
   3. Materials and information posted on our Website or our Apps are not intended as advice and should not be relied upon as such. We therefore disclaim all liability and responsibility arising from any reliance placed on such information to the fullest extent permissible by all applicable laws.
   4. You are responsible for making all arrangements necessary to access and view this Website and our Apps and should ensure you have up to date anti-virus software on any device from which your access our Website or our App.
   5. You are responsible for ensuring that all persons accessing our Website or our Apps through your internet connection are aware of these Website & App Terms of Use.
   6. We specifically reserve the right to withdraw access to our Website and/or our App and/or cancel any order in the event that you fail any credit or fraud prevention check or where we reasonably suspect fraud or money laundering by you or someone using your account.
3. Password and Account Security
   1. You are responsible for the safety and security of your password and log in details. To help protect against unauthorised access to your account you are advised to store your username(s) and password(s) safely and securely. Please ensure that your password is not one you have used before, that it is eight characters or more and, ideally, not one that you use on other sites. We recommend that you refrain from disclosing your username(s) and password(s) to anyone. We also recommend that you sign out of your account at the end of each session. You may also wish to close your browser window when you have finished your session, especially if you share a computer with someone else or if you are using a computer in a public place.
   2. If you suspect that unauthorised access has been made to your account you must notify us immediately by contacting us via this web form. We will investigate any alleged unauthorised account activity. Notwithstanding any other terms pertaining to our right to disable or block access to your account, we reserve the right to disable or block your account at any time where it is suspected that unauthorised access has been made to your account.
4. Misuse of our Website or our App
   1. You must not misuse our Website or our Apps by:
      1. knowingly introducing viruses, trojans, worms, logic bombs, time bombs, keystroke loggers, spyware, adware or other material, programme or code which adversely affects the operation of any computer software or hardware (or is designed to do so); and/or
      2. gaining or attempting to gain unauthorised access to the server on which our Website or our Apps is stored or any server, computer or database connected to our Website or our App; and/or
      3. attacking our Website or our Apps via a denial-of-service attack or a distributed denial-of service attack.
   2. Breach of this clause might constitute a criminal offence under the Irish Criminal Damage Act 1991 and/or the UK’s Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our Website and our Apps will cease immediately.
5. Users
   1. If you are aged 18 years old or over, you may create an account and become a registered user of the Website and our Apps ("User").
   2. As a User you may have access to additional products or services and/or functionality, for example, the ability to create an account, save contact information, post user generated content (“UGC”) onto the Website or via our Apps, and receive information about promotions and special offers which are restricted to Users, if any.
   3. Any personal information that you provide to us in the course of becoming a User or after registration will be held and used in accordance with any consent obtained from you and the terms of our Privacy and Cookies Policy.
   4. We also have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion you have failed to comply with any of the provisions of any of our Terms and Policies.
   5. If you know or suspect that anyone other than you knows your username or password, you must promptly notify us via this web form.
6. Posting UGC
   1. If and where the functionality of the Website or our Apps allows, Users or other visitors to the Website or our Apps that log into a social media account via any widget or interface available on or off the Website may post UGC to the Website or via our App.
   2. Any UGC posted will be attributed to the username you provide or the username of the social media account you log in with but we will not publish your email address on the Website or via our App.
   3. We reserve the right to refuse to publish any UGC (or remove without notice any previously published UGC) if it does not adhere to our User Generated Content Policy. We shall not be liable for any loss or damages whatsoever arising from such decision to refuse to publish (or to remove previously published) UGC.
   4. We also reserve the right to close the User accounts and/or ban particular users from being able to post UGC to the Website or via our Apps if they persistently and/or seriously breach the terms of the User Generated Content Policy.
   5. Views and opinions expressed in UGC submitted by Users or other members of the public are those of the individual submitting the UGC, not those of Treatwell and we accept no responsibility for the content of such UGC.
   6. However, if you find any UGC on the Website to be in any way offensive, obscene, defamatory, racist, harmful, inaccurate, unlawful, illegal or deceptive in any way, please notify us by contacting us via this web form with the subject heading "Objectionable Content". On receipt of your complaint we may remove or block access to the UGC complained of.
7. Intellectual property
   1. You may access, view and print out one copy of this Website and all information, images, and other content (except for UGC) displayed on the Website or via our Apps ("Materials") strictly in accordance with these Website & App Terms of Use.
   2. You may only view, print out, use, quote from and cite the Website and the Materials for your own personal, non-commercial use and on the condition that you give appropriate acknowledgement to Treatwell.
   3. Nothing in the above licence impairs or restricts any author's moral rights in respect of the Materials.
   4. We expressly reserve all intellectual property rights in and to the Website, our Apps and the Materials and your use of the Website, our App and the Materials is subject to the following restrictions. You must not:
      1. remove any copyright or other proprietary notices contained in the Materials; and/or
      2. use any Materials from the Website or our Apps in any manner that may infringe any copyright, intellectual property right or proprietary right of us or any third parties; and/or
      3. use, or cause others to use, any automated system or software to extract content or data from this Website or via our Apps ("screen scraping"), except in cases where you or any applicable third party has entered into a written licence agreement directly with us that expressly permits such activity; and/or
      4. reproduce, modify, display, perform, publish, distribute, disseminate, broadcast, frame (or use any other browser or border environment), communicate to the public or circulate to any third party or exploit this Website, our Apps and/or the Materials for any commercial purpose, without our prior written consent by way of a licence agreement.
8. Trade marks
   We expressly reserve all rights in and to the https://www.treatwell.ie/ domain name and all related domains and sub-domains, the name "Treatwell", our logo device, service marks, trading names and/or trade marks. Other trade marks, products and company names mentioned on the Website or via our Apps may be trademarks of their respective owners or licensors and the rights in such marks are reserved to their respective owners or licensors.
9. Linking to our Website
   1. You may link to any page of the Website, for non-commercial purposes provided that you do so in a way that is fair and legal and which does not damage our reputation or take unfair advantage of it. For the avoidance of doubt, the linking site must not contain any adult or illegal material or any material that is offensive, harassing or otherwise objectionable.
   2. You must not link to our Website in such a way as to suggest any form of association, approval or endorsement on our part where none exists. You must not remove or obscure by framing or otherwise, advertisements, any copyright notice, or other information published on the Website.
   3. Our Website must not be framed or be subjected to any other browser or border environment on any other site.If you would like to link to our Website for commercial purposes or any purpose not included above, or if you would like to become a Partner, please contact us via this web form.
   4. We reserve the right to withdraw linking permission at any time and without notice.
10. Privacy, your personal data and cookies
    The privacy of your personal data is important to us. Please see our Privacy & Cookies Policy for details of how we will process your personal data, where it is provided to us, and how we use cookies.
11. Third party content and third party websites
    1. Our Website and our Apps may contain advertising submitted by third parties. Such third parties are solely responsible for the content of such advertising and for ensuring that it complies with all relevant legislation and regulations. We do not accept any responsibility for the content of any third party advertising.
    2. Our Website, our Apps and/or the Materials may contain links to third party websites (including those of our Partners). If you decide to visit any third party site, you do so at your own risk. We are not responsible or liable directly or indirectly for the content, accuracy or opinions expressed in such websites or the standard of goods or services available through or on such websites. Unless expressly stated otherwise, links do not imply that we are, or our Website or our Apps are, affiliated to or associated with such sites.
    3. Our communications with you may contain information sourced from third party websites. Material from a third party site will be marked as such and a link to the source website may be provided. We accept no responsibility or liability for any material supplied by or contained on any third party website which is linked from our communications with you, or any use of personal data by such a third party.
    4. The inclusion of any link in our communications with you does not imply endorsement by us of the linked site. If you decide to access linked third party websites, you do so at your own risk.
    5. Please remember that when you use a link to go from our Website or our Apps to another website, our Terms and Polices (including our Privacy & Cookies Policy) will no longer be applicable. Your browsing and interaction on any other website, including websites which are linked to ours, is subject to that website’s own terms and policies. Please read those terms and policies before proceeding.
12. Our liability
    1. To the fullest extent permissible by law, we exclude and disclaim all warranties, terms, conditions and representations that might otherwise be implied by law in relation to this Website or our Apps. In particular, we do not represent or warrant that the Website or our Apps will be error-free, free of viruses or other harmful components, or that defects will be corrected. You must take your own precautions in this respect. In any event, we will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our Website or our Apps.
    2. We do not accept liability for any failure to maintain the Website or our Apps and/or late or failed delivery of any Materials.
    3. Please note that we only provide our Website and our Apps for domestic and private use, and you agree not to use our Website or our App for any commercial or business purposes unless we have approved you as a Partner.
    4. We do not accept any liability for the following types of loss, even if the loss is foreseeable: loss of income or revenue, loss of business, loss of profits, loss of anticipated savings, loss of data or waste of management of office time.
    5. The Materials may contain inaccuracies and typographical errors. We do not warrant the accuracy or completeness of the Materials.
    6. We shall not be liable for any loss caused as a result of your actions or inactions based on the Materials available on this Website or via our Apps. However, nothing in these Website & App Terms of Use shall affect your statutory rights, and nothing in these Website & App Terms of Use shall exclude our liability for death or personal injury arising through negligence, for fraud or fraudulent misrepresentation and/or anything else that cannot be excluded or limited by us under applicable law.
13. Disclaimer
    1. The information contained on the Treatment Files is for general information purposes only. The information is provided by www.treatwell.ie and whilst we endeavour to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the information, products, services or images contained on www.treatwell.ie. Your use of any or all information, products and/or services must be based on your own due diligence and you should consult an appropriate professional for specific advice tailored to your needs and situation. Any reliance you place on such information is strictly at your own risk.
    2. You must not rely on the information on the Treatment Files as an alternative to medical advice from your doctor or other professional healthcare provider. To the extent that you require medical advice, you should consult your doctor or other professional healthcare provider.
    3. Through this website you are able to link to other websites which are not under the control of www.treatwell.ie. We have no control over the nature, content and availability of those sites and will not be responsible for them. The inclusion of links does not necessarily imply a recommendation or endorse the views expressed within them.
    4. In no event shall we be liable for direct, indirect, punitive, incidental, special, consequential or any damages whatsoever arising out of or in any way connected with the use of or performance of information, products, services or reliance on the contents of www.treatwell.ie.
14. Serviced countries
    This Website and our Apps are provided for users in Ireland only. Whilst access may be possible from outside Ireland, neither this Website nor our Apps are intended for such use and such users access the Website and our Apps at their own risk.
15. Changes to our Website & App Terms of Use
    We may change these Website & App Terms of Use from time to time, in which case an up to date version will be available via the Website and our Apps. You should check these Website & App Terms of Use regularly to ensure that you are happy with any changes. You will be deemed to have accepted any changes to these Website & App Terms of Use after you have been notified of the changes on our Website or our Apps and/ or if you continue to access or use the Website or our Apps, where the updated Website & App Terms of Use will be available for you to view.
16. Legal compliance and applicable law
    The Irish Courts will have non-exclusive jurisdiction over any claim, dispute or non-contractual obligation arising from or related to a visit to this Website or use of our Apps. Irish Law will apply to these Website & App Terms of Use.
17. Contact us
    If you have any concerns or queries about material which appears on our Website or our Apps or if you have questions about your use of this Website, our Apps or these Website & App Terms of Use please contact us via this web form. Our postal address for correspondence is Treatwell, Fairfax House, 15 Fulwood Place, London, WC1V 6HU.

Introduction

This privacy and cookies policy ("Privacy Policy") details data used on www.treatwell.com and www.treatwell.ie (the "Websites"), the Treatwell Customer mobile application software and the Treatwell Connect (salon diary and management tool) application software and website at connect.treatwell.ie (“Connect”), both of which are available for download from iTunes and Google Play (the "Apps"), customisable websites powered by Connect hosted at unique subdomain addresses on mytreatwell.ie (the “Partner Sites”), and the web interfaces, also powered by Connect, embedded on Partner Sites and on our salon partners (“Partners”)’ own websites and social media pages, through which customers can make bookings directly with Partners at widget.treatwell.ie (the “Widgets”) (together, the “Platform”).

The data controller for your information is Treatwell 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: customer.care@treatwell.ie or dpo@treatwell.com.

Treatwell Limited shares your personal information with other entities in its corporate group ("Group Companies") for the purposes described in this notice. The Group Companies also process your personal data as data controllers as necessary for the purposes described in this notice. The Group Companies are listed in the section of this Privacy Policy called “Sharing personal information with third parties”, along with their contact details.

We are committed to protecting the privacy of our users and customers. This Privacy Policy is intended to inform you how we gather, define, and use information that could identify you, such as your name, email address, address, other contact details or online identifiers, other information that you provide to us when using the Platform ("Personal Information") and also what Cookies we use. Please take a moment to read this Privacy Policy carefully.

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.
• Information about your visits to and use of the Platform, such as information about the device and browser you are using, your IP address and location, your identifier for advertisers (IDFA), the date and time that you visited, the duration of your visit, the referral source and website navigation paths of your visit and your interactions on the Platform including the salons and treatments you are interested in. Please note that we may associate this information with your Treatwell account. Please see the cookies section of this Privacy Policy for further information on the purposes for which we collect and use this information.

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.

If you plan to submit someone else's Personal Information to us, for instance when making a booking on their behalf, you should only provide us with that third party's details with their consent and after they have been given access to information about how we will use their details, including the purposes set out in this Privacy Policy.

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 tailor and personalise marketing notifications and advertising for you and others based on information you provide and your use of our Platform, products and services and other sites (please see the Cookies section of this Privacy Policy for further information)
  • To help us monitor, improve and protect our Platform, products and services, and to personalise our Platform, products, services (and those of our partners) for you, based on information you provide and your use of our Platform, products and services and other sites (please see the Cookies section of this Privacy Policy for further information)
  • 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 place cookies and use similar technologies in accordance with the Cookies section of this Privacy Policy and the information provided to you when those technologies are used
  • 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 customer.care@treatwell.ie.

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 customer.care@treatwell.ie. 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:

• To any of our Group Companies for the purposes identified in this Privacy Policy. A list of local Group Company entities and their locations is as follows:

• • Treatwell Limited: Fairfax House, 15 Fulwood Place, London, WC1V 6HU, help@treatwell.co.uk
  • Treatwell IE, branch of Treatwell Limited: Fairfax House, 15 Fulwood Place, London, WC1V 6HU, customer.care@treatwell.ie
  • Treatwell LT UAB: J. Basanavičiaus g. 15, 03108 Vilnius, Lithuania, hello@treatwell.lt
  • Treatwell Spain s.l.Calle Labastida, 10-12, 28034 Madrid, Spain, servicio.cliente@treatwell.es
  • Treatwell IT s.r.l.: Via Aldo Manuzio, 17, 20124, Milano, Italy, assistenzaclienti@treatwell.it
  • Treatwell FR: 2 Rue Breguet, 75011, Paris, France, service.client@treatwell.fr
  • Treatwell BNL B.V.: Nieuwezijds Voorburgwal 120-126, 1012 SH Amsterdam, Netherlands, info@treatwell.nl
  • Treatwell DACH GmbH: Greifswalder Str. 212, 10405 Berlin, Germany, koenigkunde@treatwell.de
  • Treatwell DACH GmbH, Zweigniederlassung Zürich: Haggenholzstrasse 83b, 8050 Zürich, koenigkunde@treatwell.ch
  • Treatwell DACH GmbH, Zweigniederlassung Wien: Badhausgasse 18-20, Top 1-3, Lerchenfelderstraße 95-97, 1070 Wien, koenigkunde@treatwell.at

• 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 Media agencies and advertising partners in order to run targeted marketing campaigns (please see the Cookies section of this Privacy Policy for further information on online advertising practices)
• 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).

Stripe

We use a third party payment processor, Stripe, to process all payments made by you on our Website & App. Treatwell does not store credit card details and instead relies on Stripe for this. We obtain limited information from Stripe such as the last four digits, the country of issuance and the expiration date. The processing of such data by Stripe is covered by their privacy policy which may be viewed here: https://stripe.com/privacy

Stripe’s services in Europe are provided by a Stripe affiliate, Stripe Payments Europe Limited, an entity located in Ireland. In providing its payment processing services, Stripe Payments Europe Limited transfers personal data to Stripe, Inc. in the US. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of Stripe’s privacy policy entitled “International Data Transfers.

PayPal Transactions

Please note that all PayPal transactions are subject to the PayPal Privacy Policy which can be found here: https://www.paypal.com/uk/webapps/mpp/ua/privacy-full. Please ensure that you are happy with the terms of the PayPal Privacy Policy if you wish to use PayPal to complete any transactions through the Platform

spa.lastminute.com

The spa.lastminute.com page is powered by Treatwell. Treatwell performs certain functions as a data controller in partnership with lastminute.com, also a data controller, and as a result Treatwell is required to process your personal information and share some of that information with lastminute.com when you browse and/or book on spa.lastminute.com. The purposes for which Treatwell collects, processes & shares your personal data with spa.lastminute.com are: (i) to fulfil a contract with you, by: (a) processing & managing your bookings; and (b) communicating with you about your booking; and (ii) to fulfil our, or third parties', legitimate interests, by: (a) providing search results; (b) communicating with you, including via Treatwell’s lastminute.com branded customer service function via telephone and email; and (c) on behalf of the relevant venue, collecting your consent (if you choose to provide it) at the checkout page to receive marketing emails from the particular venue with whom you are booking. As well as collecting personal information directly from you during the booking process, Treatwell also uses Cookies (defined below) on spa.lastminute.com in order to ensure spa.lastminute.com works correctly, to enhance and simplify your user experience, to enable us to understand how many users visit our spa.lastminute.com, to establish the source of your booking (channel, location, etc.) and consequently to enable verification of the booking as a lastminute.com booking and to send lastminute.com branded transactional communications to spa.lastminute.com customers. Please see the cookies section of this Privacy Policy for further information on the purposes for which we collect and use this information. For information on retention of your personal data, transfers of your personal data (to third parties and outside the European Economic Area), and your rights in respect of your personal data, please refer to the relevant sections of this Privacy Policy. If you have any queries or wish to exercise any of your rights in respect of the personal data processing described in this paragraph, please contact Treatwell using the details set out in this Privacy Policy.

Treatwell will also, on behalf of and under the instructions of lastminute.com, collect your consent (if you choose to provide it) at the checkout page to receive marketing emails from lastminute.com and pass this to lastminute.com daily via a secure data feed. For the avoidance of doubt, Treatwell does not collect any marketing opt-in for itself on spa.lastminute.com. lastminute.com also use cookies and similar tracking measures on spa.lastminute.com to collect information about your behaviour and for other purposes including personalisation, analytical and advertising and re-marketing. Please see lastminute.com's privacy policy here and cookie policy here for more information on how lastminute.com collects and processes your personal data. If you have any queries or wish to exercise any of your rights in respect of the personal data processing described in this paragraph, please contactlastminute.com using the details set out in their privacy policy.

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 customer.care@treatwell.ie. 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.

Please remember that when you use a link to go from our Platform to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including websites which have a link on our Platform, is subject to that website's own rules and policies. Always read over those rules and policies before proceeding.

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.

Changes to our Privacy Policy

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 customer.care@treatwell.ie.

Retention

We retain your Personal Information for as long as is required to fulfil the activities set out in this Privacy Policy, otherwise communicated to you or for as long as is permitted by applicable law. For example:

• 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

In common with other commercial websites and apps, our Platform use standard technologies including cookies and similar tools including web server logs, web beacons, tokens, pixel tags, local storage, device identifiers and tracking IDs (together referred to as "Cookies" in this Privacy Policy) to enhance your user experience, improve our site and provide tailored offers on Treatwell and other sites.

Please see the table below for a live breakdown of the Cookies that are used on our Platform: