Privacy policy

This Privacy Policy (the “Policy”)  describes the policies and procedures of Flair Software Inc., (the “Company”, “we”, “our” or “us”) for the collection, use, storage, transfer and disclosure of information by us, through our Website, www.getflair.ca (the “Website”), which includes its applications, widgets or online services owned or controlled by the Company. This policy applies to all registered users, visitors of the Website and Service Providers of Flair.

Your privacy is important to us. It is our policy to respect your privacy regarding any information we may collect from you across our Website.

Please go through this Privacy Policy carefully in order to understand how the Website collects, stores, uses, discloses, retains, and protects your information. If you do not provide the information which the Website requires, we may not be able to provide Services (as defined in our Terms of Service) to you.

Personal Data” is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data. The data subjects are identifiable if they can be directly or indirectly identified, especially by reference to an identifier such as a name, an identification number, location data, an online identifier or one of several special characteristics, which expresses the physical, physiological, genetic, mental, commercial, cultural or social identity of these natural persons. In practice, these also include all data which are or can be assigned to a person in any kind of way.

By accessing or using our Services and/or registering an Account on our Website, you agree to your information being handled as described in this Privacy Policy. However, you have utmost control over your data, and you are hereby being informed about your choices regarding the use, access and correction of your information. Any dispute over privacy of your information is subject to this Privacy Policy and applicable Terms of Service, including its applicable resolution of disputes and limitations on damages. The Terms of Service www.getflair.ca/terms-of-service are incorporated by reference into this Privacy Policy and, for the sake of brevity, are hereinafter referred to as “Terms of Service”.

This Privacy Policy also outlines the rights that you have, as a User of the Website, in relation to the information which we collect from you. Users of the Website (includes the Barber Shops, Salons, Salon Experts, third party vendors (“Service Providers”) and the Clients who create their own account on the Website to provide services to the Clients who register themselves for booking appointments with various Service Providers for their requirements, respectively) as defined in the Terms of Service at www.getflair.ca/terms-of-service. By submitting information on our Website, you confirm that you have the right to authorize us to process your data on your behalf in accordance with this Policy.

A Service Provider is a salon or a salon expert having entered into a valid contract with us and working at a Salon on rent a chair basis, in Canada, offering their expertise and services to customers across the city, and desirous of listing, displaying and selling their expertise and services facilitated through the Website to such customers who visit, register and book appointments for such services for a consideration

Please note that you shall not be able to have any access to our Services in case you do not provide us with your information considering that you need to create an account with us to be able to avail our Services. In case the same is not acceptable to you, please refrain from creating an account on our Website. Creation of an account on our Website would signify your consent to the use of your information by us.

1. Scope Of this policy

  • This Privacy Policy shall apply to all Service Providers and Clients who create their accounts on our Website for the purposes of providing and availing Services, respectively. 
  • This Privacy Policy shall further apply to all Users of this Website who may access this Website, irrespective of whether they are casually browsing or accessing the Website to gain knowledge about our Services or for any other purposes, whatsoever.
  • This Privacy Policy shall become automatically applicable on the Service Providers who submit their information to us for the purposes of registering with us as a Service Provider.
  • Any reference to the term “you” throughout this Policy shall mean and include the Service Providers, the Clients and the other users of this Website.
  • The Data Controller for the purposes of GDPR shall be FLAIR Software Inc.

2. Information we collect

  • During the course of our connection with you, we collect certain information about you. The same has been detailed hereunder:

2.1 Information collected from the Clients seeking services

  • Basic Information: Personal data, which you may share with us while registering on the Website or the portal made available to the Service Providers (the “Vendor Portal”) including your first and last name, business name and contact information like your mobile number, your address and your email address;
  • Demographic information: like your birthday, age, gender;
  • Profile Picture: which you may allocate to your Account upon registering with us;
  • Device Identification data: including information which may assist us to identify your device, including your IP Address, login information, browser type and version, your operating system, etc.
  • Conversations with us: Content of reviews posted by you on our Website, emails, chats shared with us by you for any purposes, whenever you may choose to connect with us regarding our services, for dispute resolution purposes, customer care services, surveys, inquiries, etc.
  • Financial Information: like your credit card number, your preferred method of payment, transaction details, transaction number in case of any no show or cancellation charges being levied as per our policies, etc.,
  • Other data: which we may collect from you during the course of your engagement with us including:
    • Preferred location, i.e. the location where you usually book your appointments
    • Average booking time
    • Preferred means of using our Services, viz. whether manually (via calls), mobile application or Website
    • Whether you’re a recurring Client or not. If yes, we collect data about frequency of your visits;
    • Whether you use our mobile application or web application or both;
    • Number of times you, the Client, have not shown up after fixation of your appointment with the Service Provider;
    • Number of times, you, the Client, have cancelled your appointment with the Service Provider;
    • The average amount which you pay as a tip to the allocated barber/service provider and the total amount you have paid in tips till date;
    • Loyalty points that have accumulated owing to continued usage of our services, number of Loyalty points redeemed and the balance of Loyalty points left to be redeemed;
    • Referrals, viz. Number of clients one Client has referred to us for using our Services, total income generated from such referrals to the Client;
    • Whether you book your appointment in advance or at the last minute and whether you book your appointment via mobile,   or whether manually;
    • All of your booking history including information about the specific barber/ Service Provider you book your appointments with and whether you are their repeat customer;
    • Average day of the week on which you book your appointments and average time for which you book your appointment with the Service Provider;
    • Statistics about whether you open the push notifications sent to you and likelihood of opening such notifications;
    • Usual time at which you use our Website or mobile application and the amount of time spent on our Website or mobile application, etc.
    • Data which may be legally required to be collected from you for the purposes of your authentication, identification or verification.

2.2 Information collected from the Service Providers

  • Basic Information: Personally data, which you may share with us while registering on the Website for provision of services, including your complete name, and contact information like your mobile number, your address and your email address;;
  • Business related information: Information pertaining to your business like the name of your business, contact details of your business including business email address, business Website, business phone/mobile number, type of business, etc.
  • Profile Picture: which you may allocate to your Account upon registering with us;
  • Device Identification data: including information which may assist us to identify your device, including your IP Address, login information, browser type and version, your operating system, etc.
  • Conversations with us: Content of emails shared with us by you for any purposes, whenever you may choose to connect with us regarding the services provided by you, for dispute resolution purposes, customer care services, surveys, inquiries, etc.
  • Demographic information: viz. in case you are an individual who is creating an account with us for provision of services, then your date of birth and your gender.
  • Other data: which we may collect from you during the course of your engagement with us including:
    • average booking times for your business
    • average amount spent on services availed at your business
    • Average amount tipped to the Service Provider by the Client
    • List of scheduled upcoming and past appointments
    • Schedule of working hours/availability of the Service Providers
    • Services offered by the Service Providers and the price associated with the said service, including the upgradation of price over time and dates associated with such times
  • Other data which may be legally required to be collected from you for the purposes of your authentication, identification or verification.

3. Means of collection of your data

Most of your personal or other data is provided by you whenever you register or create an account with us as a Client or have a subscription with us as a Service Provider or whenever you use our Website.

3.1 Information collected automatically

  • Data that is collected automatically as soon as you create an account with our Website (for example, your personal data).
  • Data that is generated as part of one of your transactions or that is linked to your account as a result of a transaction in which you are involved, such as transaction amounts, card details, time and location of transactions.
  • Data that is generated through your other actions when you use our Website and which is linked to your account on our Website, e.g. when you surf our Website to look for various Service Providers
  • Data regarding all other interactions with our Website and your communications with us.

3.2 Personal Data we collect in connection with the use of cookies and similar technologies

  • We use cookies, web beacons and similar technologies to collect data in connection with our Services. We collect this data from the devices (including mobile devices) that you use to avail our Services. The data collected includes the following usage and device-related information:
    • Data about the pages you visit, the access time, frequency and duration of visits, the links on which you click and other actions you take as part of your use of our Website and in email content.
    • Data about your activities and interactions with us including data about the push notifications, when and where they were shown, and whether you took any action, such as clicking on it and opening the app.
    • The user segment or category into which you as a user fall, for example: female, 18-40 years old, interested in XYZ barber or XYZ services.
    • Model or device type, operating system and version, browser type and settings, device ID or individual device identifier, individual device token, and cookie-related data (e.g. cookie ID).
    • The IP address from which your device accesses our Services.
    • We do not collect or store your location data.

3.3 When the information is automatically collected by software:

  • We and  the Service Providers may also employ software technology known as “web beacons” and/or “tracking tags” to help keep track of what content on our Website is effective. Web beacons are small graphics with a unique identifier that may be invisible to the user, and which are used to track the online activity of internet users. Web beacons are embedded in the web pages reviewed or email messages received. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Website, to monitor how users navigate the Website, to count how many emails that were sent were actually opened, or to count how many particular articles or links were actually viewed.

3.4 COOKIES

  • When you use our Website, we  use cookies and similar technologies to provide you with a better, faster and safer user experience. Cookies are small text files that are automatically created by your browser and stored on your device when you use the Website.
  • The cookies and similar technologies used in connection with the services which the Website is providing have different functions listed below:
    • They may be technically necessary for the provision of our services.
    • They help us optimise our Services technically (e.g. monitoring of error messages and loading times).
    • They help us improve your user experience (e.g. save font size and form data entered).
    • They help us in recognising you whenever you sign-in to your account on our Website which would help us personalise your experience with our services.
    • They allow us to show you more relevant marketing and promotional information. Please note that we do now allow third party advertisement.
    • They help us in understanding and keep track of your preferences.
    • They also help us in analysing the performance of our services.
  • You are also free to disable the use of cookies and similar technologies if this is supported by your device. You can manage your cookie settings in your browser or device settings.

3.5 Personal Data collected from Other Sources

  • We may also collect information about you from other sources, to the extent permissible by law. In particular, the same includes the following data:
    • Data from public sources, for example, demographic information;
    • Data from data providers;
    • They help us improve your user experience (e.g. save font size and form data entered).
    • Data from government agencies, to the extent permissible by law in order to verify your identity;
    • Data from financial institutions, only in relation to the Service Providers who are registering on our Website to provide Services in order to enable us to verify their status.

4. Purpose for collection of your data

  • We collect your personal data lawfully and in a transparent manner and only when we have a legal basis for doing so. We collect and process your personal data for various legal and permissible purposes. For example, we process your personal data to provide and improve our services, to enable the Service Providers to contact you with respect to your appointments and send personalised marketing notifications to you about upcoming deals on your favourite Service Providers, to provide customer service and to detect, prevent, mitigate and investigate fraudulent or illegal activity. When you consent to our use of information about you for a specific purpose, you have the right to change your mind any any time (however, this will not affect any processing that has already taken place)

4.2 We process your personal data in order to allow you to use our Services as a Client or as a Service Provider

  • For provision of our Services: We collect your personal data in order to process your registration on our Website as a Client or as a Vendor/Service Provider, to enable you to use our Services provided via our Website, to respond to your queries, to enable the Client and the Service Provider to connect with each other and all other ancillary services which we may provide to you from time to time in lieu of your usage of our Website.
  • For displaying your transactions and booking history to you: We collect and retain your data in order to provide you with your booking history and your transaction related history to enable you to keep a record of it.
  • For enhancement of our Services: We process your data, your feedback, the issues encountered while using our Services through our Website or technical glitches encountered by you to continuously upgrade and improve our services.
  • For providing recommendations: based on your booking history, including but not limited to recommending the Service Provider chosen by you in the past (based on your satisfaction level with their services), providing you with notifications about upcoming promotions or deals, providing you with information about change in pricing of services provided by the Service Provider, sharing information about new Service Providers that may register with us from time to time, etc.
  • Providing general customer support: including the solution of problems with your usage of our Website, management of disputes, providing other services within the scope of customer service as well as enforcement of fee claims. For these purposes, we may contact you via notification in email, telephone, SMS, push notification on your mobile device or by mail. If we contact you by telephone, in order to ensure efficiency, we may use automatically dialled calls with tape announcements or automated text messages in accordance with our Terms of Service, to the extent permitted by applicable law.
  • Processing of general location data: (such as IP address or postal code) in order to provide you with specific location-based services (such as radius search to enable you to understand which Service Provider is the closest to you and other content that is personalised on the basis of your general location data).
  • Enforcement of our Terms of Service.

4.3 We process your personal data in order to comply with legal obligations to which we are subject. This includes the following purposes:

  • Participation in investigations and proceedings (including judicial proceedings) conducted by public authorities or government agencies, in particular, for the purpose of detecting, investigating and prosecuting illegal acts.
  • Prevention, detection and mitigation of illegal activities (including but not limited to fraud, money laundering or terrorist financing).
  • Complying with information requests from third parties based on any statutory information rights they have against us (e.g. in the event of an intellectual property infringement, product piracy, or other unlawful activity).
  • Ensuring the information security of our Services.
  • Retention and storage of your personal data to comply with specific legal retention requirements.

4.4 We process your personal data in order to protect your vital interests or the vital interests of another natural person. This includes the following purposes:

Prevention, detection, mitigation and investigation of unlawful activities that may result in impairment of your vital interests or the vital interests of another natural person, unless there is a statutory obligation to this effect.

5. Duration of retention of your data

  • Unless you request that we delete certain information, we shall retain your personal data for an indefinite period, either in the form in which you have submitted it to us or in the form of backups or copies made for business continuity purposes. If you have provided us with personal data, we encourage you to routinely update the data to ensure that we have accurate and up-to-date information about you.
  • Your data shall be safely retained by us after the same has been provided to us. Hence, we shall not delete your personal data even after you have stopped using our Services for the following reasons:
    • Provision of Services: We shall retain your data to effectively provide you with Services through our Website. Further, we shall retain your data for such things as executing the Terms of Service with you, maintaining and improving the performance of our products, keeping our systems secure, and maintaining appropriate business and financial records.
    • Statutory or contractual or other similar obligations: Corresponding storage obligations may arise, for example, from laws or official orders. It may also be necessary to store personal data with regard to pending or future legal disputes. Personal data contained in contracts, notifications and business letters may be subject to statutory storage obligations depending on national law.

6. Data sharing

  • We may share your data with third party Service Providers for the purpose of enabling them to provide their services, including (without limitation) IT Service Providers, data storage, web-hosting and server providers our employees, contractors and/or related entities; courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you.
  • We do not share user information with any third parties for the purposes of direct marketing unless consented to by you, and any sharing of information shall only happen with the affiliates, vendors, employees and representatives of Flair.
  • We may use data processors for providing some elements of services. But we have contracts in place with them. This means that such third parties shall process the data only in accordance with the terms of the contracts and with the objective to provide the requested services. Such third parties shall hold your personal data securely and retain it for the period instructed, in accordance with appropriate data retention policies.
  • In some circumstances we may be legally obliged to share your personal data such as in the event that the information is sought under a court order or where Flair is cooperating with other Canadian/American/European supervisory authorities in handling complaints or investigations. We might also share information with other regulatory bodies or law enforcement agencies in order to further their, or our, objectives. In any scenario, before sharing any personal data of the user we will satisfy ourselves that there is a lawful basis on which to share the information and shall document such decision making and satisfy ourselves on the subject of having a legal basis to share the information.
  • Your personal data is only shared by us, with your consent, for the purposes set out in the present Policy. In order to enable a seamless flow of Services, we shall share your personal data with:
    • If you are a Client: Your personal data shall be processed in accordance with this Policy and shared with the Service Provider on a need-to-know basis. Hence, the Service Provider shall only be made aware about your personal data and information which is extremely necessary for provision of Services. Further, we shall share your banking or credit card details with our payment Service Provider, viz. “Stripe” for the purposes of processing payments seamlessly. We also share your information with third party servers who store your data for safety and our payment processor, Stripe, who assist us in payment processing, storage and retention of your information.
    • If you are a Service Provider: Your personal data and data regarding your business shall be shared with the Client [including whatsoever you choose to disclose regarding your service providers] through our Website. Further, your financial information shall be shared with our payment Service Provider, “Stripe” for the purposes of processing payment related transactions seamlessly.
  • We share your personal data with our third party database service provider, who shall securely store your personal data.
  • We share your information with our officers and employees for the purpose of processing your personal data on your behalf, and it is ensured that these recipients of such information agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.

7. Safety of your data and storage

  • We take all reasonable and necessary steps to protect your personal data during transmission by using encryption protocols and software, however no security measures can be 100% foolproof.
  • We use SSL encryption to protect your data against unauthorised access and loss of data.
  • We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, processing, and disclosure of personal data and only users who have permission by the administrator can access your data at the back-end.
  • All our servers, including web servers and third party database servers, are housed and maintained in secure locations. Access to our servers is strictly monitored and protected from outside access. Internet access is restricted and protected by multiple firewalls. The servers on which we store personal data (ie. names, addresses) are kept in a secured environment, inside a secured and locked room. All backups are stored and locked in a high-level security room. Only personnel with proper security clearance have access to these restricted areas.
  • It is important for you to protect yourself against unauthorised access to your password and to your computers, devices and applications. You must be sure to sign off when finished using a shared computer.
  • Your data is safely and securely stored on a third-party database, i.e. Amazon Web Services, specifically employed by us for the purpose of secure storage of your personal data.

8. Your rights as a data subject

You, as a data subject, have certain rights to the personal data which has been provided by you to us. We have enlisted the same, hereunder:

  • As a registered user on the Website, you can update your choices of communication that you may receive in the course of your interaction, or you can opt out of receiving any marketing communication, or receiving push notifications, or any other promotional communication.
  • You can access the information which has been retained by us by visiting the “Your Account” section of our Website which would display information supplied by you to us. Information which you shall find in that section would be:
    • Status of all of your appointments [past and upcoming]
    • Your complete transaction history
    • They help us improve your user experience (e.g. save font size and form data entered).
    • Your personal data, like your name, email, password, contact details)
    • Loyalty points (including your balance and the points redeemed in the past)
    • In the event that you’re a Service Provider, all details about your past and upcoming appointments, all client related information which was shared with you and all transaction related information may be accessed by you.
    • Should you require any further access to the information retained by us, you may contact us at: info@getflair.ca.
  • We ensure to keep your data up to date. Further, you can request us to update/correct your information which is in our records. To exercise this option, you may reach out to us at: info@getflair.ca
  • You can exercise your rights as a data subject via our Website per the details contained within the present Policy. The aforementioned exercise of your rights is free of charge.
  • You have the right to ask us to rectify information that you find inaccurate, or to complete the information that is otherwise incomplete.
  • You have the right to ask us to erase any and all personal data that we have collected and are holding in certain circumstances. Please note that we may not be able to honour all requests for deletion of your personal data since certain information may be required to be retained either to meet the requirements of law or for the purpose of audit or for the purpose of maintaining business continuity. In addition, if you have yourself posted information which is publicly available, we may not be able to honour requests for deleting the same.
  • You have the right to ask us to restrict the processing of your personal data in certain circumstances.
  • You have the right to ask us to transfer the information that has been shared by you from one organisation to another, or ask for it to be given back to you. But such right shall apply only if we are processing the information of the user based on his consent, or we are having a communication with the user for entering into a contract and the processing is automated.
  • Flair works to high standards when it comes to processing user’s personal data. If you have any queries or concerns, you can address the same vide complaint to the info@getflair.ca, and we shall duly respond.
  • The Website may include links to third party Websites, plug-ins, services, and applications. Clicking on such links or enabling connections to such third party Websites, plug-ins, services, and applications may allow respective third parties to collect or share data about you. We neither control nor endorse these third party services and are not responsible for their privacy statements. When you leave the Website or access third party links through the Website, we encourage you to read the privacy policy of such third party Service Providers.
  • If we receive personal data about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal data about somebody else, you represent and warrant that you have such person’s consent to provide the personal data to us.
  • You may choose to restrict the collection or use of your personal data. If you have previously agreed to us using your personal data for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal data, we will let you know how the restriction affects your use of our Website or products and services.
  • You may request details of the personal data that we hold about you. You may request a copy of the personal data we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal data we hold about you at any time. You may also request that we transfer this personal data to another third party.
  • If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
  • We will comply with laws applicable to us in respect of any data breach.
  • If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
  • To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

9. Changes to this policy

    We may change this Policy in order to meet with the changing requirements of the business or law, from time-to-time, per our sole discretion. Any material changes or updates made to this Policy may be notified via a notice on our Website or via email to you. If you are a Service Provider, changes to this Website’s Privacy Policy may be notified to you via your dashboard. Further, the Effective date subsequent to changes shall be indicated at the top section of this Policy with the title: “Last Updated On”.

    Contact Us

    FLAIR Software Inc.