Privacy Policy

This policy explains how we collect and use your personal data when you visit simonetrichology.co.uk, buy from us or use our free Hair Clinic, and the rights you have under UK data protection law (the UK GDPR and the Data Protection Act 2018).

1. Who we are

The controller of your personal data is [SELLER], [SELLER ADDRESS] (“we”, “us”, “our”). You can contact us about anything in this policy by email at [SELLER EMAIL], by phone on [SELLER PHONE] or by post at the address above. We are registered with the Information Commissioner’s Office (ICO) under number [ICO NUMBER].

We are the official UK distributor of SIMONE TRICHOLOGY. TRICHOMEDIC LABS, S.L.U. (Spain), which makes SIMONE TRICHOLOGY products, provides and maintains this website for us and reviews Hair Clinic cases on our behalf. It acts as our processor under a written agreement (see section 4).

2. The personal data we use and why

2.1 Orders and deliveries

• Data: your name, email address, phone number, billing and delivery addresses, the products you order, amounts, the payment method and its status (we never see your full card details), any order notes, our messages about your order, and the IP address and browser information recorded with your order.
• Why: to process and deliver your order, take payment, keep you updated, and handle cancellations, returns, refunds and complaints.
• Lawful basis: performance of our contract with you; and our legal obligations to keep accounting and tax records.
• How long: six years from the end of the tax year in which you placed your order, after which it is deleted.

2.2 Questions and complaints

• Data: your name, contact details, the content of your messages and, if relevant, your order details.
• Why: to answer your questions and deal with your complaints.
• Lawful basis: performance of our contract with you where your message is about an order; otherwise our legitimate interest in replying to people who contact us.
• How long: up to two years after our last contact. Messages about an order are kept with that order.

2.3 Hair Clinic: free online hair and scalp analysis

• Data: your first name and email address; your answers to the questionnaire (age, sex, hair type, scalp condition, chemical treatments, your main concern and how it has developed, previous treatments, and any associated factors you choose to tell us about, which may include health information such as hormonal changes, stress or medication); up to three photos of your hair and scalp; and the preliminary reading and assessment prepared for you.
• Why: to prepare your cosmetic assessment and recommended care routine, have your case reviewed by a specialist, send the assessment to you by email and, if you come back for a follow-up analysis, compare your previous and new photos.
• Lawful basis: your explicit consent, which you give in the Hair Clinic form. You can withdraw it at any time by writing to [SELLER EMAIL]; this does not affect the processing already carried out. Without this information we cannot provide the analysis.
• Artificial intelligence: your answers and photos are analysed with artificial intelligence (Claude, provided by Anthropic PBC), which generates a preliminary reading that is shown to you immediately. A member of the SIMONE TRICHOLOGY trichology team then reviews your case, normally within 24 hours, before your assessment is emailed to you. We do not make decisions about you that have legal or similarly significant effects based solely on automated processing.
• How long: 180 days from your analysis, after which your case, including the photos, is deleted automatically. If you start a follow-up analysis within that time, your previous case is kept until the follow-up is deleted. You can ask us to delete it sooner at any time.
• The Hair Clinic is intended for adults aged 18 and over.

2.4 Product reviews

• Data: the name you choose to show, your review and rating, the product, and the fact that you bought it from us.
• Why: to publish genuine reviews from verified buyers.
• Lawful basis: your consent when you post a review. You can ask us to remove it at any time.
• How long: while the review is published.

2.5 Website security and operation

• Data: your IP address, browser and device information, the pages you request and the date and time of each request, and the contents of your basket.
• Why: to make the website and your basket work, to keep the website secure, to prevent fraud and abuse, and to fix technical problems.
• Lawful basis: our legitimate interest in running a secure website that works properly.
• How long: server and security logs are kept for up to [LOG RETENTION PERIOD] and then deleted, unless we need them to investigate a security incident. Details about cookies are in our Cookie Policy.

2.6 Marketing

We do not currently send newsletters or marketing emails, and we do not use advertising cookies. If we start, we will only send you marketing emails with your consent or, if you are already a customer, about similar products, with a simple way to opt out in every message, and we will update this policy first.

2.7 Legal claims and compliance

Where necessary, we use your data to establish, exercise or defend legal claims and to respond to lawful requests from public authorities, on the basis of our legal obligations or our legitimate interests.

3. Where your data comes from

Almost all the data we use comes directly from you. Our payment providers tell us whether a payment has been completed, and our delivery company tells us about the status of your delivery.

4. Who we share your data with

• TRICHOMEDIC LABS, S.L.U. (Spain), the manufacturer of SIMONE TRICHOLOGY products, which provides and maintains this website, gives us technical support and reviews Hair Clinic cases on our behalf, as our processor.
• Raiola Networks (Spain), which hosts this website and its email service, as a processor.
• Cloudflare, Inc. (United States), which delivers the website quickly and protects it against attacks, as a processor.
• Anthropic PBC (United States), which provides the artificial intelligence used for the Hair Clinic preliminary reading, as a processor. It may not use your data to train its models.
• Our payment providers ([PAYMENT PROVIDERS]), which process your payment and use your data to prevent fraud and meet their legal obligations, as independent controllers under their own privacy policies.
• Our delivery company ([CARRIER]), which receives your name, delivery address and contact details to deliver your order and send you tracking updates.
• Our professional advisers, such as our accountant, and HMRC or other public authorities when the law requires it.
• If our business is sold or transferred, the buyer, who will use your data in line with this policy.

Our processors only act on our instructions and must keep your data secure. We never sell your personal data.

5. International transfers

TRICHOMEDIC LABS and Raiola Networks are in Spain, in the European Economic Area, to which UK law allows personal data to be transferred. Cloudflare and Anthropic are in the United States. Cloudflare is certified under the UK Extension to the EU-US Data Privacy Framework (the “UK-US data bridge”), and transfers to Anthropic are protected by the UK International Data Transfer Addendum to the EU standard contractual clauses. You can ask us for a copy of these safeguards.

6. Your rights

You have the right to:

• ask for a copy of your personal data (access);
• ask us to correct inaccurate data, or to complete incomplete data;
• ask us to delete your data;
• ask us to restrict how we use your data;
• object to our use of your data where we rely on our legitimate interests;
• receive the data you gave us in a commonly used, machine-readable format, or ask us to send it to another organisation (portability);
• withdraw your consent at any time, where we rely on it.

Some of these rights only apply in certain circumstances. To exercise any of them, email [SELLER EMAIL]. We may need to confirm your identity first. We will reply within one month; if your request is complex, we may extend this by up to two further months and will tell you why. There is normally no charge.

7. Complaints

If you are unhappy with how we use your personal data, please complain to us first by emailing [SELLER EMAIL]. We will acknowledge your complaint within 30 days, look into it and tell you the outcome without undue delay.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK data protection regulator: ico.org.uk/make-a-complaint, helpline 0303 123 1113.

8. Security

This website uses an encrypted connection (HTTPS). Access to personal data is limited to the people who need it, and our processors are bound by contract to keep it secure.

9. Children

This website and the Hair Clinic are not intended for children under 18, and we do not knowingly collect their personal data.

10. The SIMONE Hair Scanner app

The SIMONE Hair Scanner mobile app is provided by TRICHOMEDIC LABS, S.L.U., which is responsible for the personal data processed in the app under its own privacy policy, available in the app and at simonehair.com/privacy-policy.

11. Changes to this policy

We may update this policy from time to time. We will publish the new version on this page with a new “last updated” date and, if the changes are significant, we will let you know.