Privacy Policy

Introduction

The following privacy notice outlines how Devor Systems Ltd trading as Phorest collects, processes and protects your personal data. Phorest is a software company that provides services including provision of software to salons and other businesses to manage their business, online booking services and SMS delivery.

Personal Data Collected

The personal data that we collect is:

• Name
• Address
• Email Address
• Date of Birth
• Phone number
• Identification documentation
• Consultation forms
• Health information
• Appointment data & associated notes
• Tax & banking details, where appropriate (to bill customers, set up Direct Debits)
• Payment card details
• Marketing preferences
• CCTV images (of The Skin Edit Co's premises & vicinity)

Purpose and Legal Basis for Processing Your Data

Phorest takes your privacy seriously and will never sell or rent your personal data to any third party. Sharing of your data and direct marketing activities are only carried out with your express consent, which you are free to withdraw at any time. We need to obtain and process your personal data to provide you with our products and services, to assist our business clients with the running of their operation, and to fulfil our business and legal obligations.

Where we request sensitive personal data from you (i.e. health or medical data), the reason(s) for the request will be clearly given along with the purposes of the processing. Explicit consent through a signature will always be required for us to obtain and process your health information.

Your personal data is collected and processed for the following reasons:

• In the performance of a contract for our business clients to sell products or services (name, address, email, contact number, DOB).
• Through legitimate interest to engage in communication with you including confirmation and reminders of appointments, and requests to cancel or change bookings.
• Health information is collected for our business clients to perform the agreed services appropriately, to potentially highlight areas that products and services may cause issues to clients because of their health and provide industry standard advice.
• As part of our legal obligation for business accounting, tax and insurance purposes.
• As required by law or to respond to legal process.
• To select relevant offers, promotions and information for you.

Who Is Processing My Data?

Phorest, 9 Anglesea Row, Smithfield, Dublin, D07 W5NE, Ireland are the data controller and process your personal information for the purposes laid out in this privacy notice. Phorest also acts as data processor on behalf of client businesses and have access to personal information only in cases where customer support or troubleshooting is required by clients. They must process the personal information in accordance with this Privacy Notice and applicable data protection law.

Your Rights as the Individual

If your personal data is held by Phorest, you hold particular rights over it. Where you have provided consent for us to contact you as part of our marketing services, you have the right to modify or withdraw your consent at any time by using the unsubscribe option in any of our direct marketing communications or by contacting the Phorest Data Protection Officer.

You also have the right:

• To be informed of how your personal data will be used before it is collected.
• To access your personal data and to receive information on how your information is used after it has been gathered.
• To have personal data corrected if it is incomplete, inaccurate or out-of-date.
• To request the removal or deletion of personal data where there is no compelling reason for its continued processing.
• To restrict processing — to 'block' processing of your personal data.
• To data portability, having your data moved, copied or transferred from Phorest to another organisation in an easily readable format.
• To object to direct marketing from us.

Special Categories of Personal Data

Health questions are asked in many of our business clients' consent forms to potentially highlight treatments that may have a negative effect on your health due to medication you are taking or a condition you have. Phorest asks for consent prior to gathering and processing this information. At any time after giving consent, you can withdraw your consent, subject to legal, insurance and contractual restrictions.

Process of Collection

Your personal data is collected when you provide it to us through Phorest software, our website, over the phone, in Phorest salons, by email, social media, in writing or any other means by which you provide it to us. Information is stored using the Phorest software platform.

Children's Privacy

Client businesses do not collect the personal data of children under the age of 18 without parental or guardian consent. If you believe that we hold any information from or about a child under age 18, please contact Phorest and if we cannot immediately obtain appropriate parental or guardian consent, we will remove the personal data from storage.

Data Sharing

Your personal data is shared only with Phorest representatives in cases where customer support and troubleshooting is required for the salon. Phorest does not share your personal information with any third party without your prior consent, other than those already disclosed in this privacy notice or as part of our legal obligations under the relevant data protection laws.

Use of Data Processors

Data processors are third parties who provide some elements of our business services for us. Where we use a third party, we have strict agreements in place governing the processing of your personal data, on which no action can be taken without instruction from us. The third parties with whom we work will never share or disclose your personal information and will hold it securely at all times.

Clients utilise software provided by Phorest to manage their business, including but not limited to accepting bookings, organising appointments and taking payments.

How Long Do We Keep Your Data?

Phorest retains your personal data for as long as necessary to provide you with our services. Phorest is required under tax laws to keep your personal data for a minimum of 7 years. Health and Safety records will be retained for 10 years. Where we have your consent for marketing purposes, we will retain the minimum required data until you notify us that you no longer wish to receive such information.

The criteria for which we would continue to process your personal information includes:

• Where there is a legal basis, obligation or legitimate interest to continuing processing your personal information.
• Where processing is necessary for the establishment, exercise or defence of legal claims.

Cookies

A 'cookie' is a small piece of data sent from a website and stored on the user's computer by the user's web browser while the user is browsing. Our website relies on cookies to carry out certain functions and to tailor your user experience. You can delete or block these cookies, but if you do so some features of this site may not work as intended.

Transfers of Personal Information

When personal data of persons located in the EU is processed through Phorest software, all of it is held within the EU. Your information is processed by the Phorest software and stored in the Amazon Web Services cloud infrastructure. During this process your data is encrypted in transit and at rest.

Safeguarding Your Personal Data

Appropriate measures are taken to protect your personal data from access by unauthorised persons. Your connection to the Phorest system uses a HTTP Secure communication protocol and TLS security, meaning all information passed to the Phorest system is encrypted during data input and transfer to the cloud. Any paper files recording your personal data are held in a locked filing cabinet or safe which can only be accessed by authorised personnel.

Complaints

If you want to make a complaint about how your personal data was gathered or how it is being processed by Phorest, you retain the right to lodge a complaint directly with the supervisory authority and Phorest's Data Protection Officer.

Data Protection Supervisory Authorities:

• Data Protection Commissioner, Canal House, Station Road, Portarlington, Co. Laois, Ireland R32 AP23 — +353 (0) 57 8684800
• Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF — +44 (0) 303 123 1113

Phorest Data Protection Officer / GDPR Owner

The data protection officer for the organisation is Garrett Ahern. All GDPR / data protection information requests must be communicated to Phorest as follows: contact Phorest's Data Protection Officer by email at gdprdpo@phorest.com or in writing to Data Protection Officer, Phorest, 9 Anglesea Row, Dublin 7, Ireland. Information requests being made on behalf of a third party are not accepted by email and must be communicated solely in writing.