Privacy policy

The Hair Growth Specialist cares a lot about your privacy. We therefore only process data that we need for (the improvement of) our services and treat the information we have collected about you and your use of our services with care. We never make your data available to third parties for commercial purposes.

The Hair Growth Specialist uses the collected data to provide her customers with the following services:

• If you place an order, we need your name, e-mail address, delivery address and in some cases payment details in order to process your order and to keep you informed of its progress.
• We may use your email address to make you one-time special offers in connection with your order. For our newsletter you must register yourself (opt-in). Unsubscribing is possible via our website and via a link in the newsletter.
• Data about the use of our site and the feedback we receive from our visitors help us to further develop and improve our site.
• If you decide to write a review, you can choose whether you want to add your name or other personal data. We recommend using a pseudonym. We are curious about the opinions of our visitors, but reserve the right not to publish contributions that do not comply with our site conditions.

This privacy policy applies to the use of the website and the services provided by The Hair Growth Specialist. The commencement date for the validity of these conditions is 19-04-2019, with the publication of a new version the validity of all previous versions expires. This Privacy Policy describes what data about you is collected by us, where this data is used for and with whom and under what conditions this data may be shared with third parties. We also explain to you how we store your data and how we protect your data against misuse and what rights you have with regard to the personal data you provide us.

If you have any questions about our privacy policy, please contact our privacy contact person, you will find the contact details at the end of our privacy policy.

About the data processing

Below you can read how we process your data, where we store it or have it stored, which security techniques we use and for whom the data are transparent.

Website host

Shopify

Our online store is hosted by Shopify. Personal data that you make available to us for the benefit of our services will be shared with this party. Shopifiy has access to your data to provide us with (technical) support, they will never use your data for any other purpose. Shopify is obliged to take appropriate security measures on the basis of the agreement we have concluded with them.

E-mail and mailing lists

Drip

Our website uses Drip, a third party that handles the sending of any newsletters. Drip will never use your name and email address for its own purposes. At the bottom of every email sent automatically via our website you will see the ‘unsubscribe’ link. If you click this link, you will no longer receive an email from our website. This can seriously reduce the functionality of our website! Your personal data is stored securely by Drip. Drip uses cookies and other internet technologies that monitor whether emails are opened and read. Drip reserves the right to use your data to further improve the service and to share information with third parties as part of that service.

Payment processors

PayPal

To process (part of) the payments in our online store we use the platform of PayPal. PayPal processes your name, address and residence details as well as your payment details such as your bank account or credit card number. PayPal has taken appropriate technical and organisational measures to protect your personal data. PayPal reserves the right to use your data to further improve the service and to share (anonymized) data with third parties. PayPal will, in the case of an application for a deferred payment (credit facility), share personal data and information regarding your financial position with credit rating agencies.

All the above mentioned safeguards with regard to the protection of your personal data also apply to the parts of PayPal's service for which they engage third parties. PayPal will not store your data for longer than permitted by law.

Mollie

To process (part of) the payments in our online store we use the platform of Mollie. Mollie processes your name, address and residence details as well as your payment details such as your bank account or credit card number. Mollie has taken appropriate technical and organisational measures to protect your personal data. Mollie reserves the right to use your data to further improve the service and to share (anonymized) data with third parties. Mollie will, in the case of an application for a deferred payment (credit facility), share personal data and information regarding your financial position with credit rating agencies.

All the above mentioned safeguards with regard to the protection of your personal data also apply to the parts of Mollie's service for which they engage third parties. Mollie will not store your data for longer than permitted by law.

Klarna

For concluding and processing (part of) our payments in our webshop we use the payment provider Klarna. Klarna processes your name, address and residence information. They also process payment information such as your bank account number or credit card number. Klarna has implemented fitting technical and organisational measures to protect your personal data. Klarna retains the right to use your personal (anonymised) information to further improve their services and, within this context, share it with third parties. In case of a request for a postponed payment (credit facility) Klarna will share personal and order information with the appropriate payment provider. All the aforementioned guarantees in regard to the protection of your personal data are also applicable to any services by Klarna that uses third parties. Klarna does not store your data any longer than the instalments permitted by the appropriate legal grounds.

Reviews

WebwinkelKeur

We collect reviews via the platform of WebwinkelKeur. If you leave a review via WebwinkelKeur then you are obliged to provide a name and email address. WebwinkelKeur shares this data with us, so that we can link the review to your order. WebwinkelKeur also publishes the name you have given on its own website. In some cases WebwinkelKeur may contact you to provide an explanation of your review. In the event that we invite you to leave a review, we will share your name, email address, customer ID and order number with WebwinkelKeur. They use this information only for the purpose of inviting you to leave a review. WebwinkelKeur has taken appropriate technical and organisational measures to protect your personal data. WebwinkelKeur reserves the right to engage third parties for the delivery of the service, for this we have given permission to WebwinkelKeur. All the above mentioned safeguards with regard to the protection of your personal data are also applicable to the parts of the service for which WebwinkelKeur engages third parties.

Feedback Company

We collect reviews via the Feedback Company platform. If you leave a review via Feedback Company, you are obliged to provide your name, place of residence and email address. Feedback Company shares this information with us, so that we can link the review to your order. Feedback Company also publishes your name and place of residence on its own website. In some cases, Feedback Company may contact you to provide an explanation of your review. In the event that we invite you to leave a review, we will share your name and email address and information regarding your order with Feedback Company. They only use this data for the purpose of inviting you to leave a review. Feedback Company has taken appropriate technical and organisational measures to protect your personal data. Feedback Company reserves the right to engage third parties for the delivery of the service, for this we have given permission to Feedback Company. All the above mentioned safeguards with regard to the protection of your personal data are also applicable to the parts of the service for which Feedback Company engages third parties.

Shipping and logistics

Active Ants

If you place an order with us, it is our task to have your package delivered to you. We use the services of Active Ants to carry out the deliveries. It is therefore necessary for us to share your name, address and place of residence with Active Ants. Active Ants will use this information only for the purpose of carrying out the agreement. In the event that Active Ants engages subcontractors, Active Ants will also make your information available to these parties.

External Sales Channels

Bol.com

We sell (a part of) our products via the Bol.com platform. If you place an order via this platform, Bol.com will share your order and personal data with us. We use this information to process your order. We treat your data confidentially and have taken appropriate technical and organisational measures to protect your data against loss and unauthorised use.

Amazon

We sell (a part of) our products via the Amazon platform. If you place an order via this platform, Amazon will share your order and personal data with us. We use this information to process your order. We treat your data confidentially and have taken appropriate technical and organisational measures to protect your data against loss and unauthorised use.

Purpose of the processing of data

General purpose of the processing of data

We only use your data for the purpose of providing our services. This means that the purpose of the processing is always directly related to the order you give. If you share data with us and we use this data to contact you at a later date - other than at your request - we will ask you for explicit permission to do so. Your data will not be shared with third parties other than to comply with accounting and other administrative obligations. These third parties have all been kept confidential on the basis of the agreement between them and us or an oath or legal obligation.

Automatically collected data

Data that is automatically collected by our website is processed for the purpose of further improving our services. These data (e.g. your IP address, web browser and operating system) are not personal data.

Cooperation in tax and criminal investigations

In appropriate cases, The Hair Growth Specialist may be obliged to share your information in connection with governmental tax or criminal investigations by the authorities. In such a case, we will be forced to share your data, but we will oppose it within the limits of the law.

Storage Periods

We keep your information as long as you are our client. This means that we keep your customer profile until you indicate that you no longer wish to use our services. If you indicate this to us, we will also regard it as a request to be forgotten. Based on applicable legal obligations we must store invoices with your (personal) data, so we will store this data for as long as the legal period of 7 years after the purchase is in effect.

Your rights

On the basis of the applicable Dutch and European legislation, you as a data subject have certain rights with regard to the personal data that are processed by or on behalf of us. We will explain below what these rights are and how you can invoke them.

In principle, in order to prevent misuse, we will send transcripts and copies of your data only to your already known email address. In the event that you wish to receive the data at another email address or for example by post, we will ask you to provide proof of identity. We keep records of completed requests; in the event of a request to forget, we administer anonymized data. You will receive all transcripts and copies of data in the machine-readable data format that we use within our systems.

You have the right to file a complaint with the Data Protection Authority at any time if you suspect that we are using your personal data in the wrong way.

Right of access

You always have the right to view the data that we process (or have processed) and that relate to your person or are traceable for that purpose. You can submit a request to that effect to our contact person for privacy matters. You will then receive a response to your request within 30 days. If your request is granted, we will send you a copy of all data to the email address known to us with an overview of the processors in possession of this data, stating the category under which we have stored this data.

Right of rectification

You always have the right to have the data that we process (or have processed) and that relate to your person or are traceable for that purpose, modified. You can submit a request to that effect to our contact person for privacy matters. You will then receive a response to your request within 30 days. If your request is granted, we will send you a confirmation that the data has been changed at the email address known to us.

Right to restriction of processing

You always have the right to limit the data we process (or have processed) that relate to your person or are traceable to it. You can submit a request to that effect to our contact person for privacy matters. You will then receive a response to your request within 30 days. If your request is granted, we will send you a confirmation at the email address known to us that the data will no longer be processed until you cancel the restriction.

Right to transferability

You always have the right to have the data that we process (or have processed), relating to your person or that can be traced back to you, carried out by another party. You can submit a request to that effect to our contact person for privacy matters. You will then receive a response to your request within 30 days. If your request is granted, we will send you transcripts or copies of all information about you that we have processed or that have been processed by us by other processors or third parties at the email address known to us. In all probability, in such a case, we will no longer be able to continue to provide services, because the safe linking of data files will then no longer be guaranteed.

Right of objection and other rights  

If the occasion arises, you have the right to object to the processing of your personal data by or behalf of The Hair Growth Specialist. If you object, we will immediately cease data processing in anticipation of the handling of your objection. If your objection is well-founded, we will make transcripts and/or copies of data that we process or have processed available to you and will then permanently cease processing. You also have the right not to be subjected to automated individual decision-making or profiling. We do not process your data in such a way that this right applies. If you believe that this is the case, please contact our contact person for privacy matters.

Cookies

Google Analytics

Via our website, cookies are placed from the U.S. company Google, as part of the "Analytics" service. We use this service to keep statistics of and receive reports on how visitors use the website. This processor may be obliged to provide access to these data on the basis of applicable legislation and regulations. The statistics are anonymous. The data is not shared with other Google services or third parties and it is not used for behavioural targeting.

Lucky Orange

This site uses the Lucky Orange analytics system to help improve usability and the customer experience. Lucky Orange may record mouse clicks, mouse movements and scrolling activity. Lucky Orange may record keystroke information that you voluntarily enter on this website. Lucky Orange does not track this activity on any site that does not use the Lucky Orange system. Information about Lucky Orange cookies is available here.

Discreet shipping

We do not only guarantee your privacy on the internet, but also outside of it. That is why all our orders are sent very discreetly.

Changes to the privacy policy

We reserve the right to change our privacy policy at any time. On this page you will always find the most recent version. If the new privacy policy affects the way in which we process already collected data relating to you, we will notify you by email.

Contact information

The Hair Growth Specialist

Tivolilaan 205

6824 BV Arnhem

The Netherlands

Phone number +31 85 047 1132

E-mail contact@hgspecialist.com

Contact person for privacy matters

Stefan Rumen