Parlon Privacy Notice
Last modified on 8 October 2021
We, in Parlon Beauty and Wellness Technologies, Inc. (“Parlon”, “we”, “us”, “our”), value and respect the privacy of your Personal Information as we revolutionize a better way to book and buy beauty and wellness services. Parlon adheres to the privacy principles of transparency, legitimate purpose, and proportionality. Parlon shall comply with the Philippine Data Privacy Act of 2012 (“DPA”), its implementing rules and regulations (“DPA IRR”), and other relevant policies and issuances of the National Privacy Commission (“NPC”).
This Privacy Notice and its Addendum(s) (“Notice”) describes how we collect, use, process, and disclose your Personal Information through face-to-face or electronic communications in any form and the use of Parlon’s publicly accessible websites and mobile applications (“Parlon Apps”) that are created, developed and made available by Parlon (collectively “Parlon Channels”), as well as products, features, platforms, and other services, operated by Parlon (collectively “Parlon Services”).
We enter into an agreement with beauty salons and wellness centers (“Merchant Partners”) to provide Software-as-a-Service (“SaaS”) solutions set out in Section I (Our Services). When entering into an agreement with Merchant Partners, Merchant Partners shall review and consent to Merchant Partner Terms and Conditions, which contain provisions pertaining to the use and sharing of Personal Information. This Notice does not apply and does not cover Personal Information that you may directly and independently provide to our Merchant Partners anytime.
I. OUR SERVICES
Parlon is a technology company which provides an online platform for Customers/Users to book and buy services provided by Merchant Partners which utilize Parlon's platform and cloud-based SaaS solutions (“Parlon Services”).
“Contact” refers to any person, manually added by the Merchant Partner, who is not a Parlon Registered User and is not a Customer of any Merchant Partner.
“Customer” refers to any person who is seeking or may seek beauty and/or wellness Services through the Parlon Channels, and/or who transacts with any of the Merchant Partners.
“Parlon Registered Users” refers to Customers who have successfully registered for a Parlon account using any of the Parlon Channels.
For our Merchant Partners to manage data and use Parlon Services, we provide the Merchant Partners an access to an interface assigned to the Merchant Partner that can be accessed by its Authorized Administrator/s to update its Parlon Page and to use Parlon Services (“Merchant Partner Hub”).
Subject to these Terms, we offer the following software services to the Merchant Partners:
1. Booking Service to make/accept/cancel/reschedule bookings of Contacts/Customers and potential customers of the Merchant Partner;
2. Coupon Service to generate and issue coupons to Parlon Registered Users, to selected Groups, and/or to selected Contacts/Customers.
3. Customer Relationship Management (“CRM”) Service which helps Merchant Partners in managing their Contacts/Customers.
4. Electronic Voucher Service to generate and sell Electronic Vouchers that can be bought and redeemed by Contacts/Customers or their respective recipients.
5. E-Magazine on which the Merchant Partners may publish articles, videos, and photos; and
6. Content Management Service to update the Merchant Partner Parlon Page, which displays its branches, operating hours, contact information, photos, promos, Service Menu, and other details.
Service Menu” refers to the collection of services of the Merchant Partner with its corresponding details like name, price, and description.
We aggregate information and content provided by our Merchant Partners. Through Parlon Channels, we allow you to do the following:
1. Book services offered by Merchant Partners
2. Claim Coupons generated and issued by Merchant Partners
3. Buy Electronic Vouchers generated and sold by Merchant Partners
4. Consume content uploaded by Parlon and Merchant Partners
5. Browse through the publicly accessible profile of the Merchant Partner consisting of different information such as, but not limited to, overview, branches, operating hours, contact information, photos, promos, and service menu (“Merchant Partner Parlon Page”)
II. PERSONAL INFORMATION THAT ARE COLLECTED
“Personal Information” refers to any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entry holding the information, or when put together with other information would directly and certainly identify an individual.
Upon registration and depending on which of the Parlon Services you use, Parlon collects different types of information from and about you and how you use Parlon Services, including:
1. first name;
2. last name;
4. mobile number;
5. address of the location for home service;
6. Instagram account;
7. Facebook account;
8. photo; and
For certain Parlon Services, such as buying E-Vouchers, we request credit/debit card, e-wallet, or other alternative payment method information (“Payment Information”). We accept online payments via our payment gateway service provider, 2C2P Philippines, Inc./ 2C2P Pte Ltd (“2C2P”). We do not store or maintain Payment Information. Payment Information are stored and maintained by 2C2P, a Payment Card Industry Data Security Standard (“PCI DSS”) Level 1 Services Provider. PCI DSS is a set of security standards designed to ensure that all companies that accept, process, store or transmit credit card information maintain a secure environment.
We will not require the collection of “Sensitive Personal Information,” such as ethnicity, race, marital status, color, political affiliations, or religious affiliations, or unless you disclose the same to us, or it is required by law.
Merchant Partner Provided Information
Through the Merchant Partner Hub, our Merchant Partners may provide the same Personal Information as listed above when our Merchant Partners manually creates a booking or add a Contact/Customer. Personal Information may only be accessed by Administrator/s assigned and authorized by the Merchant Partner to access and use its assigned Merchant Partner Hub (“Authorized Administrator/s”) as agreed in the Merchant Partner Terms and Conditions.
III. PARLON’S RELATIONSHIP WITH MERCHANT PARTNERS AND YOU
“Personal Information Controller” refers to a person or organization who controls the collection, holding, processing or use of personal information, including a person or organization who instructs another person or organization to collect, hold process, use, transfer or disclose personal information on his or her behalf. The term excludes: (1) A person or organization who performs such functions as instructed by another person or organization; and (2) An individual who collects, holds, processes or uses personal information in connection with the individual’s personal, family or household affairs.
“Personal Information Processor” refers to any natural or juridical person qualified to act as such under this Act to whom a personal information controller may outsource the processing of personal data pertaining to a data subject.
You can transact with multiple Merchant Partners. You transact with a Merchant Partner when you do any of the following through any of the Parlon Channels:
1. Book service/s offered by the Merchant Partner (“Book”)
2. Claim Coupon/s offered by the Merchant Partner (“Claim”)
3. Buy Electronic Voucher/s offered by the Merchant Partner (“Buy”)
When Parlon is an independent Personal Information Controller
Before a User transacts with any of the Merchant Partners, Parlon is the sole Personal Information Controller of your Personal Information. Parlon is an independent Personal Information Controller in respect of all Personal Information that it processes in the course of providing Parlon Services for the Merchant Partners and when you transact with the Merchant Partner.
When the Merchant Partner is a Personal Information Controller
In respect to the Personal Information managed through the assigned Merchant Partner Hub to the Merchant Partner, the Merchant Partner is a Personal Information Controller. The Merchant Partner is a Personal Information Controller of the Personal Information that it manually adds through the Merchant Partner Hub and/or Personal Information it receives when you transact with the Merchant Partner through the Parlon Channels.
Through the Merchant Partner Hub, Personal Information is added for processing by Parlon when any of the following instances occur:
1. Merchant Partner adds you as a Contact/Customer
2. Merchant Partner manually creates a booking for you
3. You transact with the Merchant Partner
In such case, Parlon is merely a Personal Information Processor, which provides SaaS solutions for the Merchant Partner.
IV. METHOD AND TIMING OF COLLECTING PERSONAL INFORMATION
We collect your Personal Information in the ways listed below.
1. Through Parlon Channels, you register to Parlon in three (3) ways.
a. By Email and completing a form
b. Facebook Login
c. Google Sign-In
2. Through Parlon Channels, you use Parlon Services such as, but not limited to:
a. booking beauty and wellness service/s;
b. buying Electronic Voucher/s;
c. claiming Coupon/s.
3. You subscribe to our mailing list or newsletters.
4. You follow us or engage with us on social media (e.g. Facebook, Instagram, Twitter, LinkedIn).
5. Through face-to-face or electronically, you submit to us inquiries or requests.
6. You disclose your Personal Information with our authorized representatives through phone calls, SMS, social media, meetings (face-to-face or virtual), emails, or letters.
7. You apply to a Parlon job post directly to Parlon or through other channels (e.g. Jobstreet, Kalibrr, Upwork, Indeed).
8. You submit your Personal Information to us for any other reasons.
We also collect your Personal Information through our Merchant Partners when they manually create a booking or add you as a Contact/Customer through their assigned Merchant Partner Hub.
Parlon is not intended for the use of minors, specifically individuals below eighteen (18) years old (“minor”). We do not allow registration of minors. We implement validation measures to prevent such registration. When completing the user profile, Parlon Channels shall only accept a date of birth entry that will result above the age of a minor. If we become aware that a minor has provided us with his or her Personal Information, we will take reasonable steps to delete such Personal Information. If anyone becomes aware that a minor has provided us with his or her Personal Information, please contact us through our contact details set out in Section XII (Feedback On This Notice and Contacting Us) below.
In some situations, you may provide Personal Information of other individuals to us. For example, you may add them as the recipient of an Electronic Voucher. If you provide us with their Personal Information, you represent and warrant that you have obtained their consent for their Personal Information to be collected, used, and disclosed as set out in this Policy.
V. COOKIES AND THIRD-PARTIES
When you visit Parlon Channels, click on our online advertisements, or visit our social media accounts, your Apps and Websites usage Information (“Usage Data”) may be collected using cookies, tags, web beacons (E.g. Facebook Pixel), scripts, advertising identifiers (E.g. Apple’s IDFA, Google Advertising ID), analytics tool (E.g. Google Analytics) and similar technology (“Cookies”).
Usage Data may include information such as, but not limited to, browser type, Internet Protocol (“IP”) address, operating system, Internet Service Provider (“ISP”), browser version, date and time stamp, accessed pages on the Apps or Websites, time spent on the pages in the Apps or Websites, general geographic location, referral URLs, cookie information, and other statistics.
VI. PURPOSES OF COLLECTED PERSONAL INFORMATION
We may use, combine, and process your Personal Information for the following purposes set forth below (“Purposes”).
The Personal Information we collect shall be used primarily to facilitate the transactions (Book, Claim, Buy) you make with our Merchant Partners and for you to use our Services, among others:
1. Properly address and answer your inquiries/questions and do the necessary verification of your identity and age;
2. Investigate and address reported concerns/issues and to inform you about steps taken or to be taken to resolve such concerns/issues;
3. Communicate relevant news, updates, or other information about Parlon, our Merchant Partners, and our Services;
4. Send relevant advertisements and promotions, and measure the effectiveness and reach of the advertising services that we utilize;
5. To provide, personalize, maintain, and improve Parlon Channels;
6. Improve Parlon Services by processing information for statistical, analytical, and research purposes to create anonymous and aggregate reports;
7. If you are applying to Parlon’s Job Post, review and/or process your job application; and
8. Other purposes which are relevant to the aforementioned purposes.
Marketing and Promotions
We may use your Personal Information to promote services and events of Parlon, our Merchant Partners, our Strategic Partners, and Advertisers. We may send you newsletters, alerts, updates, greetings, notifications, invitations, and promotional materials.
You may opt out of receiving any, or all, of these communications from us by clicking the unsubscribe link on the relevant email or message.
Legal Purposes and Organizational Changes
We may also use your Personal Information in connection with mergers, acquisitions, joint ventures, transfer of assignment, sale of company assets, consolidation, restructuring, financing, business asset transactions, or any other similar arrangements.
VII. STORAGE AND TRANSMISSION OF PERSONAL INFORMATION
We are committed in keeping your Personal Information safe and protecting against any threat to the confidentiality, availability, and integrity in the processing of your Personal Information. We use reasonable and appropriate physical, technical, and organizational privacy and security measures, such as but not limited to: access control, backup solutions, audit log.
We use Amazon Web Services (“AWS”), which complies with ISO 27018 (a code of practice that focuses on protection of personal data in the cloud), as a cloud services platform to store our content. To know more how AWS handle content, you may check AWS Data Privacy FAQ found on their official website.
VIII. LOCATION OF PERSONAL INFORMATION
As a user of AWS, we choose the AWS Region(s) in which our content is stored. For Parlon, our chosen AWS Region is Singapore. Personal Information becomes subject to the laws of the country where it is stored.
XI. DISCLOSURE OF PERSONAL INFORMATION
We do not rent, sell, or lease any Personal Information. We need to share Personal Information with our Merchant Partners and other parties for the Purposes.
With the Merchant Partners you transact with
When you transact with Merchant Partner/s, your data will be independently controlled by Parlon and the Merchant Partner concerned. Personal Information may only be accessed by Authorized Administrator/s of Merchant Partner/s as agreed in the Merchant Partner Terms and Conditions. This Notice does not apply and does not cover Personal Information that you may directly and independently provide to our Merchant Partners anytime.
With Parlon’s suppliers and strategic partners
In fulfillment of functions or services by third-party providers contracted by Parlon, it is necessary that we may provide Personal Information to our suppliers, consultants, marketing partners, and other service providers or strategics partners. This includes:
1. payment gateway service providers like 2C2P Philippines, Inc. / 2C2P Pte Ltd. ("2C2P");
2. cloud storage providers like Amazon Web Services (“AWS”);
3. data analytics providers;
4. marketing partners and marketing platform providers;
We may share your Personal Information to legal authorities, governmental or regulatory agencies where we are bound to comply with the law, legal proceedings, court orders, or other reportorial requirements.
In relation to the disclosure of and release of your Personal and/or Non-Personal Information, you hereby consent that your Personal and/or Non-Personal Information may be collected, deposited, kept, transferred, processed, or otherwise dealt with in another jurisdiction which may be outside of the Philippine jurisdiction where Parlon, its subsidiaries and affiliates, and third party partners may maintain their facilities and resources, in providing the Parlon Services.
X. RETENTION PERIOD
We retain your Personal Information for the period necessary to fulfill the Purposes outlined in this Notice unless a longer retention period is required or allowed by applicable laws and regulations. Once your Personal Information is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Information, we take steps to erase, destroy, anonymise, or prevent access or use of such Personal Information for any purpose other than compliance with this Notice, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws and regulations.
XI. PARTICIPATION OF DATA SUBJECT
In accordance with applicable laws and regulations, you have certain rights when it comes to your Personal Information.
Where you are given the option to share your Personal Information with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
However, choosing not to share your Personal Information with us or withdrawing your consent to our use of it could mean that we are unable to perform the actions necessary to achieve the Purposes of processing described in Section V (Purposes Of Collected Personal Information) or that you are unable to make use of Parlon Services. After you have chosen to withdraw your consent, we may be able to continue to process your Personal Information to the extent required or otherwise permitted by applicable laws and regulations.
We will screen and verify all requests beforehand. In order to verify your identity and authority to make the request, we may require you to provide supporting information or documentation to corroborate the request.
Once verified, we will give effect to your request within the timelines prescribed by applicable laws. If you wish to make a request to exercise your rights, you can contact us through our contact details set out in Section XII (Feedback On This Notice and Contacting Us) below.
XII. UPDATES, MODIFICATIONS, AND AMENDMENTS
We shall have the right to update, modify or amend the terms of this Policy from time to time. Please periodically review this Policy to be apprised of our latest updates. By continuing to use Parlon Channels, Merchant Partner Hub, Parlon Services, or continuing to communicate or engage with Parlon following the updates, modifications or amendments to this Notice, you signify your acceptance of such updates, modifications or amendments.
XIII. FEEDBACK ON THIS NOTICE AND CONTACTING US
For any complaints, questions, comments, issues, or requests regarding this Notice or if you wish to exercise your data subject rights, please address them to:
Parlon Data Protection Officer
Unit 409 Cityland 10 Tower 1, H.V. Dela Costa St., Salcedo Village, Makati City, 1227, Philippines