Privacy Policy

FH Hair Studio respects your privacy and is committed to protecting your personal data. This privacy notice will inform you about how we handle your personal data, your privacy rights, and how the law protects you.

FH Hair Studio operates as a franchise business. Our salons are run by group companies or independent franchisees. We may share information with our group companies or franchisees, especially when we collaborate to provide services to you. Additionally, we may share information with them to offer local promotions and deals that may interest you. These franchisees are also authorized to use your personal information as described in this policy.

Please note that our franchisees may have their own data collection and usage practices, which are not governed by this policy.

To understand the terms used in this privacy notice, please refer to the Glossary.

1. Important Information And Who We Are

Purpose Of This Privacy Notice

This privacy notice provides information on how we collect and process your personal data when you:

Visit one of our salons.
Visit our website (regardless of your location).
Sign up for our rewards card.
Register for online bookings.
Make an appointment via phone.
Use the FH Hair Studio mobile app.
Subscribe to the FH Hair Studio newsletter.

Our website is not intended for children, and we do not knowingly collect data related to children. It is essential that you read this privacy notice alongside any other privacy or processing notices we may provide when collecting or processing your data, so you are fully aware of how and why we use your data. This notice supplements other privacy notices and does not override them.

Controller

Mascolo Limited is the data controller and is responsible for your personal data (referred to as “we,” “us,” or “our” in this privacy notice). If you are a client of one of our salons, the individual salon company will also act as a joint data controller.

We have appointed a data privacy manager who is responsible for overseeing questions related to this privacy notice. If you have any questions or requests regarding your legal rights, please contact the data privacy manager using the details below.

Our Details

FH Hair Studio is a trading name of Mascolo Limited, registered in England & Wales No. 770236. Registered Office: Berkeley House, Amery Street, Alton GU34 1HN.

FAO: Data Privacy Manager

Email address: dataprotection@mascolo.co.uk

Postal address: Berkeley House, Amery Street, Alton GU34 1HN.

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we encourage you to contact us first so we can address your concerns before you approach the ICO.

Changes To The Privacy Notice And Your Duty To Inform Us Of Changes

This version was last updated on 30 May 2024.

We reserve the right to update this privacy notice at any time. Any changes will be posted on this page, and where appropriate, we will notify you by email.

It is important to keep your personal data accurate and up-to-date. Please inform us if your personal data changes during your relationship with us.

Third-party Links

Our website may include links to third-party websites, plugins, or applications. By clicking on these links or enabling connections, third parties may collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices. When leaving our website, we encourage you to review the privacy policies of the websites you visit.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:

Identity Data – includes first name, last name, username or similar identifier, title, date of birth, gender, and facial imagery.
Contact Data – includes billing address, delivery address, email address, and telephone numbers.
Transaction Data – includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data – includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data – includes your username and password, purchases or orders made by you, points on your rewards card, preferences, feedback, and survey responses.
Allergy Test Data – includes allergy test information and details of any medical conditions that might affect services.
Usage Data – includes information about how you use our website, products, and services.
Marketing and Communications Data – includes your preferences in receiving marketing from us and our third parties, and your communication preferences.

We also collect, use, and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law because this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy notice.

Except for health information and Allergy Test Data, we do not collect any special categories of personal data about you. Nor do we collect any information about criminal convictions and offenses.

If You Fail To Provide Personal Data

Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. How Is Your Personal Data Collected?

We use different methods to collect data from and about you, including through:

Direct Interactions. You may give us your Identity, Contact, Transaction, Profile, and Allergy Test Data by visiting our salons or filling in forms, or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
- Purchase our products or services.
- Make an appointment.
- Sign up for our rewards card.
- Subscribe to our service or publications.
- Request marketing to be sent to you.
- Enter a competition, promotion, or survey.
- Provide us with feedback.

Our salons and offices usually operate CCTV systems that record your image during your salon visit to ensure the security of our customers, employees, and business.

Automated Technologies or Interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. For more information on our use of cookies, please see our Cookie Policy.
Third Parties. We may receive personal data about you from various third parties as set out below:
- Technical Data from analytics providers such as Google.
- Identity, Contact, Technical, Profile, Usage, and Transaction Data from providers of technical, payment, and delivery services.

We use the services of Ve Interactive DACH GmbH (Französische Straße 47, 10117 Berlin, “Ve”). In providing its services, Ve collects personal data from users who visit our websites. For this purpose, Ve uses cookies and other similar technologies. Detailed information about the technologies Ve uses is available in Ve’s cookie policy. A listing of the purposes for which Ve collects personal data is listed in Ve’s privacy policy. Through the use of cookies, Ve collects personal data from users, especially contact information and behavioral data. Ve uses this personal information to draw conclusions about the user’s personal preferences and to personalize the user’s web experience, for example, by displaying personalized offers when visiting customer websites or similarly personalizing the customer’s website and displaying personalized advertisements when visiting customer websites or third-party websites. Ve and we are jointly responsible for the collection of personal data according to Art. 26 GDPR. Details can be found in Ve’s privacy policy.

End users can prevent the processing of their personal data by Ve by various means. The available options for preventing data processing are contained in Ve’s privacy policy, including the opt-out button under https://www.ve.com/de/datenschutzerklaerung#opting-out or using the opt-out mechanism of IAB Europe at http://www.youronlinechoices.com/opt-out-interface.

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first- and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data other than to send marketing communications to you via email, SMS message, or by telephone. You have the right to withdraw consent to marketing at any time by contacting us using the details above.

Purposes For Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the details above if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity and Types of Data Used	Lawful basis for processing including basis of legitimate interest
To register you as a new customer Data: Identity, Contact and Allergy Test	Performance of a contract with you
To provide you with your order or service which includes: (a) Manage payments, fees and charges (b) Collect and recover money owed to us Data: Identity, Contact, Allergy Test, Profile and Transaction	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Necessary for your legitimate interests (to ensure that we provide you with a safe service)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review or take a survey Data: Identity, Contact, Profile, Transaction and Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey Data: Identity, Contact, Profile, Usage and Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Data: Identity, Contact and Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Data: Identity, Contact, Profile, Usage, Marketing and Communications, Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Data: Technical, Usage and Profile	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you Data: Identity, Contact, Usage, Technical and Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)
To protect our employees, customers, premises and assets from crime Data: Identity, Contact, Transaction, Technical, Profile and Usage	(b) Necessary to comply with a legal obligation

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. To stop receiving any marketing communications from us, please follow the instructions in the ‘Opting out’ section below.

Promotional Offers From Us

We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, purchased goods or services from us, or provided us with your details when you entered a competition or registered for a promotion. In each case, you will receive marketing unless you have opted out of receiving it.

Third-party Marketing

We will obtain your express opt-in consent before we share your personal data with any third parties for marketing purposes.

Opting Out

To stop receiving marketing communications:

Contact us using the details above.
Visit your salon.
If you have the app, you can amend your preferences on the app.
To stop receiving marketing communications by email, please follow the unsubscribe link at the bottom of every email.
To stop receiving marketing communications by SMS, simply reply “STOP.”
To stop receiving marketing calls, please advise our colleague on the call.

Please note that you may need to unsubscribe from both email and SMS marketing separately if you no longer wish to receive any marketing communications from us. You may still receive some marketing messages for a short period after you update your marketing preferences while our systems are fully updated. After that, please note that you will still receive information and service updates.

Change Of Purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details above.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where required or permitted by law.

5. Disclosures Of Your Personal Data

Sharing Your Personal Data

We may have to share your personal data with the parties set out below for the purposes outlined in the table in paragraph 4 above:

Internal Third Parties, as set out in the Glossary.
External Third Parties, as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If such a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

Where Your Personal Information Is Held

Information may be held at our offices and those of our group companies, franchisees, third-party agencies, service providers, representatives, and agents as described above (see: ‘Disclosures Of Your Personal Data’ and the Glossary). Some of these third parties may be based outside the European Economic Area (EEA).

For more information, including how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the UK and EEA’.

Transferring Your Personal Information Out Of The UK And EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the UK and/or European Economic Area (EEA), for example:

With your and our service providers located outside the UK/EEA.
If you are based outside the UK/EEA.
Where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection law. This means we can only transfer your personal information to a country or international organisation outside the UK/EEA where:

The European Commission has issued an ‘adequacy decision’ in relation to that country or international organisation; or
There are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
A specific exception applies under data protection law.

These are explained below.

European Commission Adequacy Decision

The European Commission has the power to determine whether a country or international organisation provides an adequate level of protection for personal information and, if it does, to issue an ‘adequacy decision.’ The effect of such a decision is that personal information can flow from the UK/EEA to that country without any further safeguards being necessary.

It can take several years for the European Commission to issue an adequacy decision, and only a small number of countries currently benefit from one.

Other countries or international organisations to which we are likely to transfer personal information do not have the benefit of an adequacy decision. This does not necessarily mean they provide inadequate protection for personal information, but we must look at alternative grounds for transferring the personal information, such as implementing safeguards or relying on an exception, as explained below.

Transfers With Appropriate Safeguards

We may transfer your data to a third country or international organisation on this ground where we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects. The safeguards will usually include using standard data protection contract clauses approved by the European Commission.

Transfers Under An Exception

In the absence of an adequacy decision or appropriate safeguards, we may transfer personal information to a third country or international organisation where an exception applies under relevant data protection law, such as:

You have explicitly consented to the proposed transfer after being informed of the possible risks.
The transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request.
The transfer is necessary for a contract in your interests, between us and another person.
The transfer is necessary to establish, exercise, or defend legal claims.

We may also transfer information for the purpose of our compelling legitimate interests, as long as those interests are not overridden by your interests, rights, and freedoms. Specific conditions apply to such transfers, and we will provide relevant information if and when we seek to transfer your personal information on this ground.

Further Information

If you would like further information about data transferred outside the UK or EEA, please contact our Data Privacy Manager (see ‘Contact us’ above).

7. Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

We will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

How Long Will You Use My Personal Data For?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are as follows:

Your personal data will be held by each salon you have visited for as long as you remain an active client at that salon (we currently deem this to be two years from your last visit to the salon). After you cease to be an active client, we will still retain some of your details to ensure that we comply with our legal obligations and legitimate business interests.
If you have subscribed to our newsletter, your personal data will be held for as long as you remain a subscriber to the newsletter. If you choose to unsubscribe, we will keep the record of your unsubscribe request to ensure that we comply with our legal obligations.

In some circumstances, you can ask us to delete your data. Please see Your Legal Rights below for further information.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data (further details of which are contained in the Glossary):

To request access to your personal data.
To request correction of your personal data.
To request erasure of your personal data.
To object to the processing of your personal data.
To request restriction of processing your personal data.
To request transfer of your personal data.
To withdraw consent.

You can check and update your personal data each time you visit your salon. Please be aware that each salon holds its own client data. This means that if you have visited more than one salon, and provided that you are still an active client of that salon, you will need to update your personal data at each salon. If you wish to make a complaint or exercise any of the rights set out above, please contact us using the details above.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our operations to enable us to offer you the best services/products and the most secure experience. We ensure that we consider and balance any potential impact on you (both positive and negative) and your rights before processing your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to do so by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us using the details above.

Performance of Contract

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a Legal or Regulatory Obligation

Complying with a legal or regulatory obligation means processing your personal data where it is necessary to comply with a legal or regulatory obligation that we are subject to.

Third Parties

Internal Third Parties

Group companies and franchisees acting as joint controllers or processors who are based in Germany and provide IT and system administration services and undertake leadership reporting.

External Third Parties

Service providers acting as processors who provide courier services, IT and system administration services, our electronic point of sale (EPOS) system, and marketing services.
Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors, and insurers based in Germany who provide consultancy, banking, legal, insurance, and accounting services.
Local regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
Marketing platforms used to send out marketing emails or SMS messages to you.

Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. However, we may not always be able to comply with your request for erasure due to specific legal reasons, which we will notify you of at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- (a) if you want us to establish the data’s accuracy;
- (b) where our use of the data is unlawful but you do not want us to erase it;
- (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or
- (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.