PRIVACY POLICY

PRIVACY POLICY

OUR DATA PROCESSING ACTIVITIES IN GENERAL

M Company Oy (“M Company”, “we”) has developed and owns the M Room concept (“M Room Concept”) for men’s barber shops. We also provide and manage the www.mroom.com website (“Website”) and the M Room mobile application (“M Room App”).

For the purposes above M Company collects and processes personal data of users of the Website and the M Room App as well as personal data of the customers and potential customers of the M Room barber shops of M Company and/or our franchising partners (“M Room Shops”). All of the aforementioned individuals are referred to in this Privacy Policy as “Users”.

In this Privacy Policy, the Website, the M Room App and the products and services offered in the M Room Shops are collectively referred to as the “Services”.

This Privacy Policy may be updated if required in order to reflect the changes in data processing practices or otherwise. The current version can be found on the Website and on the M Room App. We will not make substantial changes to this Privacy Policy or reduce the rights of the Users under this Privacy Policy without providing a notice thereof.

Please note that this Privacy Policy only covers data processing carried out by M Company as a data controller. In this Privacy Policy, the word M Company refers solely to M Company Oy, excluding its affiliates. Therefore, the term “third party” covers also M Company’s affiliates as well as M Company’s franchising partners operating under the M Room Concept.

M COMPANY’s Contact details

Name: M Company Oy
Business ID: 2200111-9

Correspondence address: Bulevardi 30 B 1, 00120 Helsinki

Requests regarding privacy issues: privacy@mroom.com

www.mroom.com

Contact person: Niko Sandell, 040 022 8689, niko.sandell (a) mroom.com

PERSONAL DATA PROCESSED AND SOURCES OF DATA

We collect two types of information from the Users: User Data and Technical Data. Although we do not normally use Technical Data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with User Data. In such situations, Technical Data can also be considered to be personal data under applicable laws and we will treat the combined data as personal data.

M Company may process the following User Data received from the Users or from M Company’s affiliates or franchising partners:

First name

Last name

Phone number

Date of birth

Email address

Postal address

Photos and other possible files downloaded via the M Room App

Payment information relating to the payment transactions made in the M Room Shops

Services and products the User has purchased in the M Room Shops

Information relating to the User’s membership

Customer feedback and reclamations

Information relating to answers provided in connection with competitions and lotteries

In addition, M Company may collect and process the following Technical Data received from the Users:

The Users’ IP addresses

browser type and version

preferred language

operating system and computer platform

areas of our Services the User has visited

In addition to the above mentioned, we obtain User Data from registers maintained by the authorities and customer default registers as well as other reliable private and public registers.

Cookies

We use various technologies to collect and store Technical Data and other information when the Users visit the Website, including cookies.

Cookies are small text files that are placed on your computer. Cookies allow us to calculate the aggregate number of people visiting the Website and monitor the use of the Website. This helps us to improve our Services and better serve our Users and provide them with information based on their individualized needs. We may also use cookies that make the use of the Website easier, for example by rememberingpreferences. We may use tracking and analytics cookies to see how well our Services are being received by our Users.

The Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. This can usually be done through Internet browser’s settings. Information about how to manage cookies can be found online. For example, the following links provide information on how to adjust the cookie settings on some popular browsers:

Safari

Google Chrome

Internet Explorer

Mozilla Firefox

Please note that some parts of our Website may not function properly if use of cookies is refused.

Google Analytics

The Website uses Google Analytics and other web analytics services to compile Technical Data and reports on visitor usage and to help us improve the Website. For an overview of Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on.

Purposes and legitimate grounds for processing of personal data

Purposes

There are several purposes for the processing of personal data by M Company:

To provide and develop the Services


We process personal data in the first place to be able to offer the Services to the Users, to process and verify payment transactions as well as for customer verification.

We also process the personal data provided by the Users in order to develop the quality of our Services, for instance by analyzing the services and products the Users have purchased in the M Room Shops and by analyzing the areas of the Website the Users have visited.

For customer communication and marketing

We process personal data for the purpose of maintaining our customer relationships with the Users, for instance by contacting the Users regarding the Services. We also process personal data of the Users in order to inform the Users of changes relating to the Services. We use personal data for marketing and advertising the services and products provided by us, e.g. to customize the User’s experience by providing the User with targeted offers and advertising based on the information gathered from the User during his/her previous visits to the Website.

If the User contacts us to give feedback with respect to our Services, we will use the provided information for answering questions and solving possible issues.

Legitimate grounds for processing

We process personal data to perform our contractual obligations towards the Users. Furthermore, we process personal data based on our legitimate interest. Our legitimate interest is based on running, maintaining and developing our business, improving the customer or visitor experience of the Users as well as on marketing our services and products.

In some parts of the Services, the Users may be requested to grant their consent for the processing of personal data. In this event, Users may withdraw their consent at any time.

transferS to countries outside EUROPEAN ECONOMIC AREA

M Company stores the Users’ personal data primarily within the European Economic Area. However, we have franchising partners and service providers in several geographical locations. As such, we, our franchising partners and our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or the User’s domicile.

We will take steps to ensure that the Users’ personal data receives an adequate level of protection in the jurisdictions in which it is processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards, such as the Privacy Shield Framework.

More information regarding the transfers of personal data may be obtained by contacting us on any of the addresses indicated above.

recipients

We only share personal data within the organisation of M Company if and as far as reasonably necessary to perform and develop our Services. We do not share personal data with third parties outside of M Company’s organization unless one of the following circumstances applies:

For legal reasons

We may share personal data with third parties outside M Company’s organization if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of M Company, the Users or the public in accordance with the law. When possible, we will inform the Users about such transfer and processing.

To authorized service providers and franchising partners

We may share personal data with our authorized service providers who perform services for us (including data storage, sales, marketing and customer support services). Our agreements with our service providers include commitments that the service providers agree to limit their use of personal data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Policy.

We also share personal data collected from the Users with our franchising partners operating under the M Room Concept. Please note, that while we collect and process all User Data and Technical Data as data controllers in accordance with this Privacy Policy, also our franchising partners might process personal data as data controllers in accordance with their privacy policies.

For other legitimate reasons

If M Company is involved in a merger, acquisition or asset sale, we may transfer personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all Users concerned when the personal data are transferred or become subject to a different privacy policy as soon as reasonably possible.

With explicit consent

We may share personal data with third parties outside M Company’s organization for other reasons than the ones mentioned before, when we have the User’s explicit consent to do so. The User has the right to withdraw this consent at all times.

storage period

We delete or anonymise the personal data in our possession relating to the User at the latest after 6 (six) months have passed from the termination of the User account and membership of the User in our Services or when we no longer have legitimate grounds to store such data (e.g. for the purposes of processing claims relating to the purchases the User has made from us or our franchise partners or affiliates) or when we are required by law or accounting standards to store such information in the form of personal data.

We will store Technical Data relating to the Services for thirteen (13) months according to the hosts privacy policy.

Users’ rights

Right to access

The Users have the right to access your personal data processed by M Company. The Users may contact us on any of the addresses indicated above, and we will inform what personal data we have collected and processed regarding the said User.

Right to withdraw consent

In case the processing is based on a consent granted by the User, the User may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use the Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to rectify

The Users have the right to have incorrect or incomplete personal data we have stored about the User corrected or completed. By contacting us on any of the addresses indicated above, the User may update e.g. his/her contact details or other personal data. The User Data provided by the User on the M Room App may be updated on the M Room App.

Right to erasure

The Users may also ask us to delete the Users’ personal data from our systems. We will comply with such request unless we have a legitimate ground not to delete the data. Such legitimate ground may be based on e.g. applicable legislation.

Right to object

The Users may object to the processing of personal data if such data are processed for other purposes than purposes necessary for the performance of the Services to the User or for compliance with a legal obligation. In case we do not have legitimate grounds to continue processing such personal data, we shall no longer process the personal data after your objection.

Right to restriction of processing

The Users may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use the Services.

Right to data portability

The Users have the right to receive their personal data from us in a structured and commonly used format and to independently transmit those data to a third party.

How to use the rights

The above mentioned rights may be used by sending a letter or an e-mail to us on any of the addresses set out above, including the following information: name, address, phone number and a copy of a valid ID. We may request the provision of additional information necessary to confirm the identity of the User. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.

Direct marketing

If the User has provided his/her consent for receiving direct marketing or if any other lawful ground applies for such direct marketing, M Company may contact the Users for the purposes of direct marketing. This means that M Company may use the User’s personal data that it has collected in accordance with this Privacy Policy to contact the User with respect to product offers and other direct marketing.

Notwithstanding any consent granted beforehand for the purposes of direct marketing, the User has the right to prohibit us from using the User’s personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the functionalities of the M Room App or the unsubscribe possibility offered in connection with any direct marketing messages.

Lodging a complaint

The User can lodge a complaint with the local supervisory authority for data protection, in case the User considers M Company’s processing of personal data to be inconsistent with the applicable data protection laws.

Information security

We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test our Services, systems and other assets for security vulnerabilities.

 

Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of the Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.

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