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Saloon Data Processing Agreement

This is a translation of the Verwerkersovereenkomst Saloon. If the two differ, the Dutch text prevails.

This data processing agreement is an agreement between [not known yet], located at [not known yet], [not known yet] [not known yet], registered with the Netherlands Chamber of Commerce under number [not known yet] (Saloon), and the salon that uses Saloon. It belongs to the Terms and Conditions for Salons. You agree to it when you accept those terms.

In short

  • You decide which data about your customers and your team you record in Saloon and why; we process it only for you and on your instructions.
  • We do not use your salon's data for our own purposes, except for counts for our own statistics that cannot be traced back to a person (article 3.6), and unless the law requires us to.
  • We protect the data with the measures in annex B and keep each salon's data separate from that of other salons.
  • We work with the subprocessors on our Subprocessors page; we announce a new one at least 30 days in advance, and you may object to it.
  • If there is a data breach, we warn you without undue delay, and at the latest 36 hours after we discover it.
  • After the agreement ends you can export your data for 30 days; then we delete it, except the financial records the law requires you to keep for 7 years.

This is a summary; the articles below are binding.

1. Definitions

1.1 In this agreement:

  • Saloon (we): [not known yet], as described above.
  • the salon (you): the business that uses the platform and has entered into the Terms and Conditions for Salons with us.
  • the terms: the Terms and Conditions for Salons.
  • user: anybody with a login at the salon, such as the owner and the team members.
  • customer: a customer of the salon.
  • the back office: mijn.saloon.nl, where the salon and its users work.
  • the website: Saloon.nl.
  • the app: Saloon's app for customers.
  • the platform: the back office, the website and the app together, with everything that runs behind them.
  • account with Saloon: the account a customer creates on the website.
  • GDPR: the General Data Protection Regulation (Regulation (EU) 2016/679).
  • personal data: data about a person who can be identified, as meant in the GDPR. Where this agreement says "data", it means personal data.
  • processing: anything that can be done with personal data, from recording and viewing to sending and erasing it.
  • controller: whoever decides why and how personal data is processed.
  • processor: whoever processes personal data on behalf of a controller.
  • subprocessor: a company we engage that processes the salon's personal data in doing so.
  • data subject: the person the data is about, such as a customer or a team member.
  • data breach: a breach of security through which the salon's data is accidentally or unlawfully lost, destroyed or altered, or reaches somebody who may not see it.
  • EEA: the European Economic Area: the European Union, Iceland, Liechtenstein and Norway.

2. What this agreement is about

2.1 We provide the platform to the salon under the terms. In doing so we process data about customers, team members and other people the salon records in the platform. For that data the salon is the controller and Saloon is the processor. This agreement governs how we handle that data, as article 28 of the GDPR requires.

2.2 We process the data only to provide the platform to the salon: the calendar and online bookings, the customer records, the till, the team, the messages to customers on the salon's behalf and the other features the salon uses. Annex A describes which data subjects and data are involved and what we do with them.

2.3 Some data we process not for the salon but for ourselves, as controller: the accounts of users (sign-in, sessions, devices), the salon's details as our customer, accounts with Saloon, reviews, the salon profile on the website and our security logs. This agreement does not apply to that data; our Privacy Statement does. Article 15 describes where the two meet.

2.4 This agreement applies as long as the terms apply, and after that for as long as we still process the salon's data (article 13).

2.5 Annexes A, B and C form part of this agreement.

3. We act only on your instructions

3.1 We process the data only on your instructions, and those instructions are documented. Your instructions are: this agreement, the terms, and the way you and your users use and set up the platform. A question a user puts to our support is an instruction too, as far as needed to answer it.

3.2 This also applies to transferring data to a country outside the EEA (article 8).

3.3 If a law of the European Union or of a member state requires us to process the data in another way, for example because a court or a supervisory authority demands it, we tell you in advance, unless that law forbids it.

3.4 If we believe an instruction infringes the GDPR or another data protection rule, we tell you straight away. Until this is resolved, we need not carry out that instruction.

3.5 We do not use the salon's data for our own purposes: not for advertising, not to sell it and not to share it with other salons. Only where the law requires us to do we do anything else with it (article 3.3), and article 3.6 is the one exception.

3.6 You allow us to derive counts from the salon's data for our own statistics on the use of the platform: for example how many customers, appointments and checkouts a salon has, and how many online bookings come in. These are counts per salon and per day, nothing more. They hold no name, contact detail or other data of a customer or team member, we do not use them to recognise anybody, not for advertising and not to sell them, and we do not share them with other salons. For those counts we are the controller.

4. What you arrange as the salon

4.1 You are responsible for the data you record and for what you do with it. You have a lawful basis for every processing.

4.2 Allergies, sensitivities and the result of a patch test are health data: a special category under the GDPR, with stricter rules. So is what a customer fills in about their health on a form of yours. You record them only with the customer's explicit consent or on another ground in article 9(2) of the GDPR. If a form asks about health, you say so in Saloon, so that the customer gives separate consent for it. You decide which questions you ask, and you ask no more than you need.

4.3 You tell your customers and your team which data you record about them, why, and that you use Saloon for it, for example in your own privacy statement.

4.4 If you send customers advertising, you make sure you have their consent or another lawful basis. You keep the consents you record in a customer record accurate.

4.5 In free-text fields, such as notes and important information about a customer, you enter only what you really need. You enter health data or other sensitive data there only if you have a ground for it as in article 4.2.

4.6 You decide who gets a login at your salon and which role, and therefore which rights, each person has. You make sure users keep their sign-in details secret, and you remove the access of anybody who no longer works for your salon.

5. Confidentiality

5.1 Only people who work for Saloon and need the data for their work have access to the salon's data, and no more than that work requires.

5.2 They are bound to confidentiality, by their contract or by law.

5.3 We impose the same duty on subprocessors (article 7.5).

5.4 In our own management system, Saloon's staff can view the salon's log (the log is set out in article 9.5 of our Privacy statement), to help the salon or to trace a problem on the platform. Staff with the owner role can always do so; other staff only when they give a reason. Every time somebody opens the salon's log, we record who, when and, if one was given, the reason. We keep that for two years.

6. Security

6.1 We take appropriate technical and organisational measures to protect the data, as article 32 of the GDPR requires. In doing so we take into account the state of the art, the costs, the nature of the data, including health data, and the risks to the data subjects.

6.2 Annex B describes the measures.

6.3 We may change the measures, but the level of security does not go down as a result.

6.4 If you notice anything that points to a security problem, report it to us straight away at [not known yet].

7. Subprocessors

7.1 You give us general written authorisation to engage subprocessors. The subprocessors we use now are listed on the Subprocessors page at https://www.saloon.nl (annex C).

7.2 If we want to add or replace a subprocessor, we e-mail the salon owner's address at least 30 days before the new subprocessor receives any of the salon's data. At the same time we put the change on the Subprocessors page.

7.3 You can object within those 30 days, giving your reason, by e-mail to [not known yet]. We then look for a solution together.

7.4 If we find no solution before the new subprocessor starts, you can end the agreement as of that date, at no cost. Anything you paid in advance for the period after that is refunded.

7.5 We impose on every subprocessor, in a written agreement, the same data protection obligations as this agreement contains, in particular on confidentiality and security.

7.6 If a subprocessor fails to meet its obligations, we remain fully liable to you for their performance.

8. Data outside the EEA

8.1 The platform and its database run in the European Union.

8.2 A subprocessor processes the salon's data outside the EEA, or sends it there, only if the GDPR provides a ground for it: a decision of the European Commission that the country offers an adequate level of protection (article 45), such as the EU-U.S. Data Privacy Framework for a US company certified under it, or appropriate safeguards (article 46), such as the European Commission's standard contractual clauses.

8.3 The Subprocessors page states for each subprocessor where the data is processed and on which ground it leaves the EEA.

9. Requests from customers and team members

9.1 Data subjects have rights over their data, such as access, rectification, erasure and a copy (articles 15 to 22 of the GDPR). You answer those requests. We help you with appropriate technical and organisational measures.

9.2 Much of this you can do yourself in the back office: view and change the data of a customer or team member, delete a customer and export your customer list.

9.3 If a request cannot be handled in the back office, for example a complete copy of all data about a customer or erasing it permanently, ask us. We carry it out in time for you to meet the legal term of one month.

9.4 If a request reaches us about data we process for your salon, we forward it to you without undue delay. We do not answer it ourselves; we only let the sender know that we have forwarded it to the salon.

10. Help with security and risk assessment

10.1 We help you meet your obligations under articles 32 to 36 of the GDPR, as far as this fits how we process the data and what we know. This covers security, reporting data breaches (article 11), a data protection impact assessment and a prior consultation of the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

10.2 A data protection impact assessment (DPIA) is an assessment of the risks of a processing for the data subjects. If you have to carry one out or consult the Dutch Data Protection Authority in advance, we give you the information about the platform you need for it.

10.3 This help costs you nothing, unless it takes more time than is reasonable. We then agree a price in advance. Help with a data breach that arose at our end or at a subprocessor is always free.

11. Data breaches

11.1 If we discover a data breach at our end or at a subprocessor, we report it to you without undue delay, and at the latest 36 hours after we discover it. We e-mail the report to the salon owner's address.

11.2 The report states, as far as we know it:

  • a. what happened and when;
  • b. which kinds of data subjects and data are affected, and roughly how many data subjects and records are involved;
  • c. what the likely consequences are;
  • d. what we have done or propose to close the breach and limit its consequences;
  • e. whom you can contact for more information.

11.3 If we do not know everything yet, we report what we know and add to the report as soon as we know more.

11.4 We take measures straight away to close the breach and limit its consequences, and keep you informed.

11.5 You decide whether the breach is reported to the Dutch Data Protection Authority and to the data subjects. We do not report it to them on your behalf, unless you agree that with us.

11.6 We record every data breach, with the facts, the consequences and the measures.

12. Information and audits

12.1 We give you all the information you need to demonstrate that we comply with this agreement and with article 28 of the GDPR. Ask for it at [not known yet].

12.2 You may have it checked whether we comply with this agreement (an audit). The following applies:

  • a. an audit takes place at most once a year;
  • b. you announce it at least 30 days in advance;
  • c. an independent expert carries it out, bound to confidentiality;
  • d. the audit disrupts our work as little as possible and gives no access to other salons' data;
  • e. you share the report with us.

12.3 The audit is at your expense. If it shows that we fail to comply with this agreement on a material point, we pay the reasonable costs of the audit and remedy the shortcoming at no cost to you.

12.4 If a data breach at our end or at a subprocessor has shown that an audit is needed, the limit of once a year and the 30-day term do not apply.

12.5 An investigation by the Dutch Data Protection Authority is not subject to the limits in this article.

13. After the agreement ends

13.1 Until 30 days after the agreement ends, you can export your data or ask us for a copy. You receive that copy in a common machine-readable format, such as CSV or JSON.

13.2 After that we delete the salon's data, at the latest 60 days after the agreement ends. Articles 13.3 to 13.6 describe the exceptions.

13.3 Tax law requires you to keep your sales and receipts, with the customer's name and contact details as they appear on the receipt, for 7 years. You instruct us to keep those financial records for you until that term has passed. During that time we keep them restricted: we use them only to give them to you on request or to meet a legal obligation. After the term we delete or anonymise them.

13.4 If you do not want this, export the financial records and ask us to delete them. You are then responsible for keeping them yourself.

13.5 If data is also in a backup, it disappears from it when that backup is overwritten in the normal cycle. Until then we use a backup only to recover from a failure.

13.6 If a law of the European Union or of a member state requires us to keep data longer, we keep only that data, and only for as long as that law requires.

13.7 On request we confirm by e-mail that we have deleted the data.

14. Liability

14.1 For damage caused by either of us failing to comply with this agreement, the liability rules in the terms apply, with the same limitations and the same maximum. This agreement and the terms together have one maximum.

14.2 The limitation does not apply in the case of intent or deliberate recklessness (opzet of bewuste roekeloosheid) of Saloon or its management.

14.3 This article is without prejudice to article 82 of the GDPR. A data subject can therefore claim damages under that rule. Between us, each bears the part of the damage it is responsible for, subject to articles 14.1 and 14.2.

15. Bookings through Saloon.nl and reviews

15.1 Customers can book at your salon through the website, the app or the booking widget. What a customer enters when booking goes into your salon's calendar and customer records. From that moment we process that data for you, under this agreement.

15.2 If a customer books with an account with Saloon, that account is ours: we are the controller for the account and its link to your salon. The appointment and the customer record at your salon remain yours.

15.3 We publish reviews on the website as controller, under our Review Policy. You see the reviews of your salon in the back office and can reply to them.

15.4 If a customer deletes their account with Saloon, your customer record and the appointments at your salon remain. If the customer wants those erased as well, that is a request to you (article 9).

15.5 If you connect your own Google Analytics or Meta Pixel to your salon pages, Google's or Meta's software collects data for your Google or Meta account after the visitor's consent (article 14.11 of the General terms for salons). That data goes directly from the visitor's browser to Google or Meta; we neither receive nor keep it, and Google and Meta are not our subprocessors. You are responsible for that measuring. We load the software only on your instruction (the connection), only on your pages and only after consent, and we ask that consent with our cookie notice.

16. Changes, order of precedence and governing law

16.1 If we change this agreement on a point that is material to you, we e-mail you the new text at least 30 days before it takes effect. If you do not agree with it, you can end the agreement as of that date, at no cost.

16.2 Articles intended to continue after the agreement ends, such as articles 5, 11, 13 and 14, continue to apply for as long as we process the salon's data.

16.3 If this agreement and the terms say different things about personal data, this agreement prevails. If an article and an annex say different things, the article prevails.

16.4 This agreement is governed by Dutch law. A dispute is brought before the court designated in the terms.

Annex A. Description of the processing

A.1 Purpose and nature. Saloon provides the salon with the platform with which it manages appointments, customers, sales, its team and its messages to customers. We store the data, show it to the salon's users, calculate with it (such as availability and totals), send messages on the salon's behalf and make exports at its request.

A.2 Data subjects.

  • the salon's customers, including those who book online as a guest or join a waiting list;
  • emergency contacts of customers and team members;
  • the salon's team members;
  • contact persons at the salon's suppliers.

A.3 Data.

Data subject Data
Customer name, e-mail addresses, phone numbers, address with coordinates, date of birth, gender, job title, language, preferred team member, photos and documents, appointments, no-shows and cancellations, purchases, gift cards, subscriptions, tips, the messages the salon sends with their delivery, consents per channel, notes
Emergency contact name, relationship, e-mail address, phone number
Team member name, e-mail address, phone number, gender, address, job title, start and end date of employment, type of employment, absences, schedule, PIN (only as an unreadable hash), photo, internal notes
Contact person at a supplier name, e-mail address, phone number

A.4 Special and sensitive data.

  • Health: allergies (type, name, reaction, severity up to life-threatening, comment), patch tests, and the answers and signatures on client forms, with the consent the customer gave there. You decide what a form asks, so a form as a whole counts as health data.
  • Free text that may contain sensitive data: notes on a customer, the fields for important and additional information, the team alert and custom fields on the customer record, notes on an appointment or a waiting-list entry, the reason and description of a team member's absence (such as illness), and the reason a customer was blocked.
  • What a booking can reveal: a service such as medical pedicure or prenatal massage can say something about a person's health or pregnancy.

A.5 What we do with the data.

  • store, organise, display, search, change and delete it;
  • send e-mails on the salon's behalf, such as appointment confirmations, reminders, changes, cancellations, messages about a waiting list, gift card or subscription, a thank-you with an invitation to review and a reply to a review, and record whether they were delivered (not whether they were opened or clicked);
  • send push messages to team members' devices, which may contain a customer's name and an appointment;
  • show address suggestions while a user types an address;
  • keep a log of who did what in the back office, which the salon can see for two years; to be able to help the salon, we keep with it the data as it was before and after a change, which only our own staff can see and which we erase after 30 days;
  • make exports at the salon's request.

A.6 Duration. As long as the agreement runs, and after that as article 13 describes. We keep the financial records for 7 years (article 13.3).

A.7 Location. The platform and its database run in the European Union. Annex C states where each subprocessor processes data.

Annex B. Security measures

B.1 Separation between salons. The application limits every query to the data of the salon the user is working in, and refuses every change that points at data of another salon.

B.2 Roles and rights. Every team member has a role that determines what they may see and do. The server refuses what a role does not allow; it is not a matter of hiding buttons.

B.3 Signing in. We store passwords only as a hash (argon2id), never readable. A signed-in user stays signed in through a cookie that scripts in the browser cannot read. Attempts are limited: after 5 failed sign-in attempts an account is locked for 30 minutes. Users see on which devices they are signed in and can sign out the others.

B.4 Shared devices. On a device the team shares, a PIN locks the screen.

B.5 Encryption in transit. The salon's data travels only over encrypted connections (TLS).

B.6 Files. Photos and documents are kept in private storage, separated per salon, in the European Union.

B.7 Logs and error reports. We put no personal data in logs and error reports. Request contents, cookies, query parameters in addresses and sign-in details are removed from error reports before they are sent.

B.8 Hosting in the European Union. The platform, the database and the file storage run in the European Union; error reports are stored in the European Union.

Annex C. Subprocessors

C.1 The subprocessors are listed on the Subprocessors page at https://www.saloon.nl, stating for each what we engage it for, which data it receives, where it processes the data and on which ground the data leaves the EEA.

C.2 The list as it stands when you accept the terms forms part of this agreement. Changes follow article 7.