Privacy and Cookie Policy
Last updated January 2020
Introduction
This privacy and cookies policy ("Privacy Policy") details data used on
www.kookla.ca (the "Website"), and the Kookla mobile application.
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 Kookla,
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.
- 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
Kookla 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, while 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, 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 Kookla. This includes:
- Sending you information about your requested services (such as appointment reminders) by
email, SMS and push notification
- Facilitating your bookings
- Responding to your questions and concerns
- Administering your account
- As required by Kookla 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 Kookla 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 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 use customer communications for training, record-keeping and quality control
purposes. If you telephone our customer experience team, please note that the fact that
you have contacted us will be noted and your call may be recorded. You will be told if
such a recording is being made and also given the opportunity to opt-out of being
recorded if you wish to do so and the means for doing so
- To process applications for a position at Kookla, 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 Kookla, 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 Kookla 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
- 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
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 Kookla 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 help@kookla.ca
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.
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
- If you place an order or otherwise engage with Kookla 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
- 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 Kookla'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).
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 help@kookla.ca
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.
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 Kookla, 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 Kookla, 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) for the purposes set out below.
Note that third parties collect and use data from Cookies placed on the Platform. This Privacy Policy
may not describe the privacy practices of such third parties. We encourage you to read the privacy
policies of these third parties and, if you prefer to not have data reported by these parties,
follow their opt-out processes where these exist. Please review "What can I do to
change my Cookies preferences?" section below for further information.
Why do we use Cookies?
Strictly Necessary/Transactional Purposes
Using Cookies for this purpose is essential for our Platform to work correctly. They may be required
to enable you to move around our Platform and use our features, for system administration, to
prevent fraudulent activity, to keep you logged in from one page to another or so that we can
remember what you have added to your basket. These cookies cannot be switched off as our Platform
cannot function properly without them.
Functionality Purposes
Using Cookies for this purpose enables us to enhance and simplify your user experience. For example
they may remember choices you make such as the country you visit our Platform from, language, search
parameters such as date, area or treatment, and help to identify issues with our Platform (such as
crash incidents). These can then be used to provide you with an experience more appropriate to your
selections and to tailor and enhance your visits to our Platform. The information these technologies
collect may be personally identifiable, such as your log-in details. They cannot track your browsing
activity on other websites or apps outside the Platform.
Performance Purposes
Using Cookies for this purpose enables us to better understand how many users visit our Platform, how
users arrive at, and browse or use our Platform and which parts of our Platform are most popular.
This helps us to improve the Platform, such as navigation and interface experience, and improve our
products and services. To achieve this, we collect information on how people use our Platform and
use third party technologies for this purpose. We also use these Cookies to help us measure the
effectiveness of our online marketing and advertising activities. We use some third party Cookies
for this purpose. Examples:
Google Analytics is a web analysis service provided by Google, Inc. We use Google
Analytics to monitor how visitors use our Platform, to compile reports and to help us improve
the Platform. Google collects information in an anonymous form, including the number of visitors
to the Platform, where visitors have come to the Platform from and the pages they visited on the
Platform. This information is then used by Google to make reports for us and to help us improve
the site. Please see Google’s privacy policy here www.google.com/policies/privacy/
for further information on the data Google collects and how it is processed.
Targeting or Advertising Purposes
Using Cookies for this purpose enables us to display adverts on and off the Platform, and to collect
information about your browsing habits and usage of the Platform in order to make adverts more
relevant and personalised to you and your interests. We may use remarketing technologies to enable
third parties to display relevant and personalised ads to you through their networks. They are also
used to identify that you have seen a particular advert, limit the number of times you see an advert
as well as help measure the effectiveness of an advertising campaign. We use some third party
technologies for this purpose. Technologies are also placed by social media sites for advertising
and targeting purposes.
These technologies remember the sites you visit and that information is shared with other parties
such as advertisers. When we use third parties for advertising and targeting purposes, we may
disclose:
- Personally identifiable information, such as email address, order ID, venue.
- Generic, aggregated or anonymised data relating to your visits and use of our Platform; or
- Information in a pseudonymised form such as a browser cookie ID / code or cryptographic hash of
your email address to help us tailor and display our ads to you on other services. This ID or
code is matched against your equivalent unique code similarly generated by our ad partners to
tailor adverts to you.
The third party companies that we use for targeting and advertising purposes have their own privacy
policies which you should read in detail.
Examples:
Facebook Targeting. These cookies are set by Facebook. Facebook
uses cookies to manage social login and to collect data on its users’ interests. Facebook uses
this data to deliver targeted advertising during your browsing experience/ whilst you are
online.
Doubleclick Advertising. Doubleclick is Google’s real time bidding
advertising exchange. These cookies ensure that you can see Kookla offers on carefully selected
third party websites after you have left the Platform.
Google Targeting.
These cookies are set by Google. These cookies enable Google to profile the interests of
visitors and ensure that relevant Kookla advertising reaches you on third party sites or search.
These cookies may also be used to store user preferences, verify Google user accounts.
How do we use information we collect from tracking technologies?
See "How do we use your personal information?" above.
What can I do to change my Cookies preferences?
Please find below a number of ways in which you can manage your Cookie preferences online. Please
also refer to the privacy & cookie policies of the relevant third party for more
information.
- Most browsers and devices allow you to remove tracking technologies and/or
block new tracking technologies being set. To turn off tracking technologies, look at the “help”
menu on your browser, or visit your device settings. However, please note, that (a) this may not
be effective for all tracking technologies and (b) switching off tracking technologies may
restrict your use of the Sites and/or delay or affect the way in which they operate.
- AdChoices is a self-regulatory program that encourages online advertising
platforms to include an advertising option icon on any ads or webpages where data is collected
and used for behavioural advertising. Find out more here: www.youradchoices.com/control.
- Google Analytics: If you prefer to not have data reported by Google Analytics,
you can install the Google Analytics Opt-Out Browser Add-On by following the instructions here:
tools.google.com/dlpage/gaoptout. You may opt out
of Google's use of Cookies by visiting the Google advertising opt-out page here www.google.com/policies/technologies/ads/.
- Facebook Ads: You can control how Facebook uses data to show you ads by turning
off ads which may be based on interests and / or your relationship with specific advertisers, in
your ad preference settings. For further information, please visit the various Facebook pages
which allow you to learn more about Facebook ads and Cookies and to update your settings:
Please note that where you have opted out of receiving our email marketing communications via the
methods described above under the section “Withdrawing consent or otherwise objecting to
direct marketing”, 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.
In the case of third parties not specified in this section, please consult their relevant privacy
& cookies policy to find out more about adverts displayed to you whilst you are
online and how you can opt-out
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