608 West Peace Street, Raleigh, NC 27605

Privacy Policy

Privacy Policy for Adara Spa Incorporated

Introduction

The following privacy notice outlines how Adara Spa Incorporated collects, uses, protects and transfers your personal data.

Personal data collected

The personal data that we collect is:

Name
Home address
Email Address
Date of birth
Phone number
Health information

Purpose and Legal Basis for Processing Your Data

Adara Spa Incorporated take your privacy seriously and we 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, services and treatments and to full our business and legal obligations. We will never collect any personal information from you that we do not need or retain any data that is no longer necessary for the purposes specied in this notice.

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.

Who is processing my data?

Adara Spa Incorporated, 608 West Peace Street , Raleigh, NC 27605 are the data controller and processes your personal information for the purposes laid out in this privacy notice. EZtransition LLC, 4691 S Atlanta Rd SE Suite 230, Atlanta, GA 30339, United States, acts as data processor on behalf of the salon and have access to personal information only in cases that customer support or troubleshooting is required by Adara Spa Incorporated. Further, they must process the personal information in accordance with this Privacy Notice and as permitted by applicable data protection laws.

Your personal data is processed to:

Collect specic personal data (name, address, email, contact number, DOB) that is required to enter into a contract to sell a product or service.
Engage in communication with you including conrmation and reminders of appointments, and requests to cancel or change bookings.
Collect Health information to perform the agreed services appropriately, and potentially highlight areas that products and services may cause issues to clients because of their health.
Ensure a safe service and provide industry standard advice.
Select relevant offers, promotions and information for you.
Estimate the number of customers we have.
Hold personal data that is required by law or to respond to legal process. Hold for insurance purposes.
Store customer records.

Your rights as the individual

If your personal data is held by Adara Spa Incorporated, 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 accompanied with all of our direct marketing or by contacting the Adara Spa Incorporated Data Ofcer.

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 personal data and to 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 Adara Spa Incorporated to another organisation in an easily readable format.
To object to direct marketing from us.

Special categories of personal data collected

Health questions are asked in many of our 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. Adara Spa Incorporated asks for consent prior to gathering and processing this information. At any time after giving consent, you can withdraw you consent, subject to legal, insurance and contractual restrictions (see more on "your rights as an individual"). Your privacy is very important to us and we only use this information for determining your suitability for the treatment.

Process of collection

Your personal data is collected when you provide it to us through Eztransition software, our website, over the phone, in Adara Spa Incorporated, by email, social media, in writing or any other means by which you provide it to us. Information is stored using the Eztransition software platform as well as some level of paper record keeping.

Adara Spa Incorporated gives you access to information about your account and bookings through Eztransition software, for the limited purpose of viewing and updating that information.

Children's Privacy

Adara Spa Incorporated does not collect the personal data of children under the age of 13 without parental or guardian consent. If you believe that we hold any information from or about a child under age 13, please contact Adara Spa Incorporated and if we cannot immediately obtain appropriate parental or guardian consent, will remove the personal data from storage.

Data Sharing

Your personal data is shared only with EZtransition representatives in cases that customer support and troubleshooting is required for the salon. Adara Spa Incorporated 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.

EZtransition

Adara Spa Incorporated use software provided by EZtransition to manage the salon for appointment scheduling, CRM and marketing.

How Long Do We Keep Your Data?

Adara Spa Incorporated retains your personal data for as long as necessary to provide you with our services as our client. Adara Spa Incorporated 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 and 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

Consequences of not providing your personal information to Adara Spa Incorporated

In the event that you want to purchase a product or service from Adara Spa Incorporated, certain personal information is required to enter into a contract with you. Adara Spa Incorporated will not be able to enter into a contract with you to full an attempt to purchase a product or service if you do not provide your personal information.

As noted in this privacy statement, we are processing your personal data to comply with legal and statutory obligations and in the performance of a contract. You can always choose not to provide personal information; however, we will be unable to provide certain products, services and treatments in these instances.

Safeguarding your Personal Data

Appropriate measures are taken to protect your personal data from access from unauthorized persons or inappropriate access, internal or external. Your connection to the EZtransition system uses a HTTP secure communication protocol and TLS security. This means all information passed to the EZtransition 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 in the salon. Employees are only assigned specific access rights and can only access the salon software with the password assigned to them by the management of the salon.