Surge Ventures Inc. Privacy Policy

Last Updated: 25 May 2018

This is the Privacy Policy for Surge Ventures Inc. (“Privacy Policy”), and this Privacy Policy explains how and why we collect and use personal information, and what we do to ensure it is kept private and secure and in compliance with the applicable laws.

Click on any of the following sections to jump directly to that heading:

CONTENTS

  1. INTRODUCTION
  2. THE PERSONAL INFORMATION WE COLLECT
  3. COOKIES, PIXEL TAGS AND OTHER WEB BEACONS
  4. HOW WE USE YOUR PERSONAL INFORMATION
  5. LEGITIMATE INTERESTS
  6. KEEPING YOUR PERSONAL INFORMATION SAFE
  7. STORAGE AND RETENTION
  8. DISCLOSING YOUR PERSONAL INFORMATION
  9. DISCLOSURES REQUIRED BY LAW
  10. LINKS TO THIRD PARTY WEBSITES
  11. YOUR RIGHTS
  12. UPDATING THIS PRIVACY POLICY

1. INTRODUCTION

We are Surge Ventures Inc., the company behind Shedul and Fresha (“we,” “our”, “us”). When you use our apps and services, you’re trusting us with your information. We understand this is a big responsibility and we work hard to protect your information and put you in control.

This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information. For the purposes of data protection law, we will be a controller of the personal information we hold about you. This means we make decisions about how and why your information is used, and have a legal duty to make sure that your rights are protected when we use it.

Terms we use in this Privacy Policy
“Apps” the “Shedul” and “Fresha” apps available on the Google Play Store or the Apple App Store;
“End User” an individual using any of our Apps;
“Merchant” a business owner who uses the Shedul app to make bookings and engage with customers;
“Privacy Policy” this privacy policy which may be amended from time-to-time; and
“Services” any of the services we provide to merchants or individuals through our Apps and Websites (being www.fresha.com and www.shedul.com).

Who should read this Privacy Policy?

This Privacy Policy will apply to you if you are either:

  1. a Merchant on the Shedul platform;
  2. an End User; or
  3. a visitor to any of our Websites.

By accessing or using the Services or any of our Websites, you agree to the terms of this Privacy Policy. If we make any significant changes to this Privacy Policy, we will notify you through email or directly through our Apps and Websites.


Further Information

If you have any questions about our Privacy Policy, don’t hesitate to get in touch with us. Please feel free to reach out to us at [email protected].

2. THE PERSONAL INFORMATION WE COLLECT

We collect personal information (meaning anything that could identify you either by itself, or when combined with other information we are able to gain access to), as described below. You can always choose not to provide us with your personal information, but it may mean that we are unable to provide you with the Service you have requested.


Information you provide to us when creating an account

When you create an account using either of our Apps or Websites, you provide us with personal information, including your name, e-mail address, postal address, a password, the name of your business (if you are a Merchant) and your phone number (if your device has one). We also collect demographic information such as your birth date, age, gender and lifestyle. If you give us permission to do so, we may also collect information about your social media presence, including your usernames.


Information we collect as you use our Services

Apps and Browsers

We collect information about your device when you download and install one of our Apps, and about your browser when you visit either of our Websites.

The information we collect includes:


When Using Our Services

We collect personal information when you use our services. This may include:


For Merchants

If you are a Merchant, we will collect the following details about you:


Third Parties

We may receive personal information about you from other sources with which you have registered, Merchants, business partners, affiliate entities (collectively, "Partners"), or other third parties. For example, if an End User creates an account on Fresha through one of our registration partners, such as Google or Facebook, we may collect personal information from those websites. We may associate this information with the other personal information we have collected about you.


Information About Others

Through your use of the Services, we may also collect information from you about someone else. If you provide Fresha with personal information about someone else, you must ensure that you are authorised to disclose that information to Fresha and that, without Fresha taking any further steps required by applicable data protection or privacy laws, Fresha may collect, use and disclose such information for the purposes described in this Policy. See Section 0 for more about referrals. If Fresha has been given personal information about you by another user and you would not like us to retain it, please contact us using the details given in Section 1 above, and we will delete it.

3. COOKIES, PIXEL TAGS AND OTHER WEB BEACONS

A cookie is a small file of letters and numbers that we store on your browser or device if you agree. Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions. When you access these pages or open email messages, the pixel tags and web beacons generate a notice of that action to us or our service providers. These tools allow us to measure response to our communications and improve our web pages and promotions.


We use the following types of cookies:


Remarketing Cookies

You may notice that sometimes, after visiting a website, you see increased numbers of adverts from the site you visited. That’s because the website you visited has placed a cookie on your web browser. Using that cookie and web analytics tools, the website owner will be able to show you adverts on third-party websites that they think you might be interested in. This cookie does not give access to your computer or mobile device, but may be able to identify you from other details.


Google Analytics

Our Websites use Google Analytics to show relevant adverts to users who have previously visited us as they browse the web. This enables us to tailor our marketing to better suit your needs and only display ads that are relevant to you. You may see Fresha or one of our Merchants in search results pages (using Google Adwords), on YouTube, in banner adverts on Gmail and on other services run by Google.

Any information collected will be used in accordance with our own privacy policy and Google’s privacy policy. If you do not wish to see ads, you can:


Facebook Remarketing

We also use similar targeted advertising technology to ensure that we only serve people with adverts on their Facebook pages that are relevant to them. To enable us to do this, we include a piece of code on our websites, called the Facebook Pixel. The information collected, for example which pages you visited, which device you used and what actions you took, will be used in accordance with our own privacy policy, as well as Facebook’s privacy policies. The Facebook Pixel only lasts for sixty (60) days. Using the Facebook Pixel, we can also remarket adverts to you through Instagram, which is owned by Facebook. You can set preferences for how Facebook advertises to you using your Facebook ad preferences.


Opting Out of Cookies

You can refuse to accept some or all cookies by modifying settings within your browser. For guidance on how to do this, please visit http://www.aboutcookies.org. However, if you block strictly necessary cookies, you may be unable to access certain parts of our Websites. If you wish to opt out of remarketing cookies, please visit the Network Advertising Initiative Opt-out Page.

4. HOW WE USE YOUR PERSONAL INFORMATION

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


We may use personal information held about you in order to:

Your information will be treated in accordance with applicable data protection law.

5. LEGITIMATE INTERESTS

We may rely on legitimate interests to process your personal information, provided that your interests do not override our own. Where we rely on legitimate interests, these interests are:

6. KEEPING YOUR PERSONAL INFORMATION SAFE

We employ a variety of physical and technical measures to keep your personal information safe and to prevent unauthorised access to, use or disclosure of it. Databases are stored on secure servers and we control who has access to them (using both physical and electronic means).

Where we have given you (or where you have chosen) a password which enables you to access our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. We cannot absolutely guarantee the security of the internet, external networks, or your own device, accordingly any online communications (e.g. information provided by e-mail, through our Website or our Apps) are at your own risk.

7. STORAGE AND RETENTION

Where we store your personal information

We are a multinational company with group companies in the United States, United Kingdom, Poland, and the United Arab Emirates. Where possible, our data is hosted and stored within the European Economic Area or with partners protected by Privacy Shield agreements. When necessary, the information that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom and the European Economic Area (“EEA”), and may also be processed by staff operating outside the United Kingdom or the EEA who work for us or for one of our partners. Whenever data is transferred outside of the UK or EEA, we will take all steps reasonably necessary to ensure that any transferred personal information is treated securely and in accordance with applicable data protection laws.


Data Retention

Fresha will store personal data as long as Merchant accounts continue to use our software, and for a period of not more than 24 months thereafter. Users may elect to have their data removed from Fresha either by contacting the Merchant directly or by contacting users on Fresha.com. In the case that a Merchant explicitly indicates their intention to cease to use our software and have their data deleted, personally identifiable information stored with their account shall be encrypted and/or removed. Other information related to activity on the Apps will be retained for reporting and analytical purposes, or other purposes at set forth in Section 8.

8. DISCLOSING YOUR PERSONAL INFORMATION

Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent, or otherwise share the personal information that we collect with third parties, unless you ask or authorise us to do so. However, there are occasions where we may need to disclose your personal information. Where we do so, any such disclosure will be on the basis that these third parties are required to keep the information we give them confidential and secure, and will not use it for any other purpose than to carry out the services they are performing for us. We may disclose personal information as follows:


If you are a Merchant

We may share some or all of your personal information, including but not limited to booking information, staff member names, Merchant offerings, ratings and reviews, prices and discounts, appointment availability, and related data (collectively "Merchant Information") with end users who have signed up or registered for Fresha and with Fresha business partners and affiliates with which Fresha is working:


Aggregated Data

We may use aggregated non-personally identifiable data to:

9. DISCLOSURES REQUIRED BY LAW

We are subject to the law like everyone else. We may be required to give information to legal and/or regulatory authorities if they so request, or if they have the proper authorisation such as a search warrant or court order.

We also may need to retain and disclose certain personal information about you to legal and/or regulatory authorities and to appropriate agencies to conduct anti-money laundering checks and to assist with fraud prevention. We will disclose this information as is required by law.

This Privacy Policy applies solely to the personal information collected by Fresha and does not apply to third party websites. Fresha is not responsible for the privacy policies of third party websites. You should read the privacy policies of other websites before providing them with any personal information about you.

11. YOUR RIGHTS

We want you to remain in control of your personal information. Part of this is making sure you understand your legal rights, which are as follows:

If you would like further information about any of your rights or wish to exercise them, please contact us using the details given in Section 1.

Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so (for example, because the information no longer exists or there is an exception which applies to your request).

If you are not happy with our response, or you believe that your information protection or privacy rights have been infringed, you should contact the UK Information Commissioner's Office, which oversees information protection compliance in the United Kingdom. Details of how to do this can be found at www.ico.org.uk.

12. UPDATING THIS PRIVACY POLICY

We may update this Privacy Policy at any time. When we do, we will post a notification on the main page of our Website and we will also revise the updated date at the bottom of this page. We encourage users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we hold.