Privacy Policy v1.0 - SimplyBook.me booking system

1. Introduction

SimplyBook.me ltd, provides an appointment and scheduling system, that has many additional features such as promotion and marketing system, sales system and client contact system.

If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.

1.1 We are committed to safeguarding the privacy of our website visitors and our system users who register as users of our system. See Data Processing Agreement for details about our relationship as Processor and Controller concerning the data subjects of Controller.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and system users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you visit our website.

1.4 Our website incorporates privacy controls which affect how we will process your personal data. Upon signing up as a system user, you will be asked for information about your business. You can at any point in time, go to the System Settings, and choose to delete the system, and then all your data and all your client’s information will be deleted from our servers within 30 days.

1.5 In this policy, “we”, “us” and “our” refers to SimplyBook.me ltd. (30, Gladstonos Street, P. Makedonas Court, Mezzanine Floor, 3041, Limassol, Cyprus)

1.6 In this policy “clients” refers to “clients”, “students”, “patients” or anyone that makes a booking with a user of the system.

1.7 In this policy “system” refers to the appointment booking solution supplied by SimplyBook.me ltd.

2. How we use your personal data

2.1 In this Section 2 we have set out:

(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal basis of the processing.

2.2 We may process data about your use of our website and system ("usage data"). The usage data may include your company information, your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your system use. The source of the usage data is are analytics tracking system such as Google Analytics and similar. This usage data may be processed to understand better user’s behaviour to help us make the system better and to communicate with our users with usage hints. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website, system, client service and system services.

2.3 We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through the System. For example, you provide your contact information when you register for the System. You also have the option of adding a profile photo, bio, and other details to your profile information to be displayed on your Service provider profile or on your Company profile with our system so that your clients can book services with you. We keep track of your preferences when you select settings. We may process your "account data". The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and used for communicating with you. The legal basis for this processing is to be able to provide you with our system services so that you can display your information and sell services and products.

2.4 We may process your information included in your company profile in our system. ("company info"). The profile data may include your name, address, telephone number, email address, profile pictures, and other details that you add to your profile. The profile data may be processed for the purposes of enabling your use of our website and services. This information is available on the user’s booking site, supplied by us, on a widget that may be inserted into own site or in Facebook. It may also be made available on our directory sites where all system users are displayed, unless they specifically opt out of being displayed there. The legal basis for this processing is to enable proper operation of the system and services.

2.5 We may process provider’s personal data that is provided in the course of the use of our services "service provider data". The provider data may include provider’s name, address, telephone number, email address, profile pictures, and other details that is add to provider’s profile. The source of the service provider’s data is you, your employer, or the user who sets up the system for his personal or company purposes. The service providers data may be processed for the purposes of operating the system so that clients can effectively book appointments online with providers and find and select the providers they need. This information is available on the user’s booking site, supplied by us, on a widget that may be inserted into own site or in Facebook. It may also be made available on our directory sites where all system users are displayed, unless they specifically opt out of being displayed there. The legal basis for this processing is to enable proper operation of the system and services.

2.6 We may process information that you create for your bookable services, products for sale, promotions, or as company information ("publication data"). The publication data may be processed for the purposes of enabling your system to be processed for the purposes of operating the system so that clients can effectively book appointments online and purchase products and read about your business and service offering. The legal basis for this processing is to enable proper operation of the system and services.

2.7 We may process information contained in any enquiry you submit to us through email or live support regarding the system and our services "enquiry data". The enquiry data may be processed for the purposes of analysing our users problems and to make our system better.

2.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website "transaction data". The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is legal requirements for proper accounting practices.

2.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters "notification data". The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your given consent to receive this communication.

2.10 We may process information contained in or relating to any communication that you send to us "correspondence data". The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.12 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.13 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.14 Do not supply any other person's personal data to us, unless with their proper consent.

3. Providing your personal data to others

3.1 We may disclose your personal data to any member of our group of companies, this means our subsidiaries, full time work contractor staff, such as live help, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy

3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3 Financial transactions relating to our website and services are handled by our payment services providers, [Paymentwall, PayPal]. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

3.4 If you agreed on getting proposals from partners, we may disclose your enquiry data to one or more of those selected third party suppliers of goods and services enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.

3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.[ We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. International transfers of your personal data

4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA). Remark that Google, Facebook and Paypal may store data in USA. But under the privacy shield agreement.
See more about that here: https://www.privacyshield.gov/welcome.

4.2 We and our other group companies and fixed contractors have offices and facilities in Iceland, Cyprus and Ukraine. The European Commission has made an "adequacy decision" with respect to the data protection laws of Iceland and Cyprus. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. No data transfer takes place to Ukraine other than your communication in the LiveAgent support system with your support related questions. This data is stored on LiveAgent servers in EU. Read more about LiveAgent privacy here: https://www.ladesk.com/security-privacy-policy. You can grant the live support staff limited one time access to your system, to help you out with issues by specifically granting them an access key.

4.3 The hosting facilities for our system are situated in France with OVH; Amazon and Google Cloud servers, based in EU, are used for backups. Our directory Booking.Page is hosted in Canada with OVH; when you allow publication of your company info, service provider data and publication data including company reviews in the Booking.Page directory you explicitly consent to transfer this data outside EEA.
Read more about OVH security standards here: https://www.ovh.com/world/about-us/security.xml
Our email servers are situated in UK with Linode. Read more about Linode security here: https://www.linode.com/security.
Our messaging platforms are Nexmo, Sendinblue and Google
https://www.nexmo.com/privacy-policy/
https://www.sendinblue.com/legal/privacypolicy
https://privacy.google.com/

For statistics and analytics we use Google analytics, Hotjar, Piwik (self hosted in France).

We do not use this software to get personal data or relate it directly to users of our system. This is only used to give us overall overview on how visitors interact with our system so we can make it better.

For user communication related to system usage, we use a self hosted versions of marketing automation tools to avoid external access to our user's data. This allows us to track user's action within the SimplyBook.me system and send appropriate email and system messages to assist with the SimplyBook.me system usage. This tracking and communication is only used in cases where users have allowed us to communicate with them, by checking the marketing communication box during sign up.

We allow users to activate chat bots. You understand that clients are not requested to accept Terms & Conditions nor Privacy policy when they book through such tools. If you are not comfortable with this, or think this is not according to laws and regulations in your country, or for your clients, you should not use these tools to accept bookings.

For text chat bots that accept bookings, we use Google dialogflow and facebook. See Google privacy statement here: https://cloud.google.com/security/gdpr. See Facebook privacy information here: https://www.facebook.com/business/news/facebooks-commitment-to-data-protection-and-privacy-in-compliance-with-the-gdpr

For voice chat bots, we use Google dialogflow and Twilio. See Google privacy statement here: https://cloud.google.com/security/gdpr. See Twilio’s privacy policy here: https://www.twilio.com/legal/privacy.

We also use the following auxiliary system: Google Fonts, Google Charts, Google Maps, and Maxmind to make location data to help with signing up and to facilitate displaying you as service provider or your company on a map. This information is generally available for clients unless this is disabled in settings. Then address or map is not shown to clients on booking site or in directory. These external systems do not store any personal recognisable data about you.

4.4. To process credit card payments we use PayPal or SafeCharge.
We do not have any access to your credit card numbers at any of these systems. In Paypal, your name, and paypal email address are stored along with item name being purchased. See more about PayPal privacy policy here: https://www.paypal.com/uk/webapps/mpp/ua/privacy-prev, and about SafeCharge privacy here: https://www.safecharge.com/privacy-policy/.

Payment data generally falls under accounting and bank safeguarding regulations and is needed to be stored for 5-10 years at payment processors.

4.5 Accounting software
We use Notando accounting system and run this on our own dedicated servers, hosted in EU. We keep all invoicing data that contains your purchases, name, address, and email. This invoicing data must be stored obligatory for 7 years for tax authorities because of country laws and can therefore not be deleted by user’s request.

4.6 You acknowledge that personal data that you submit for publication through our system or services about you, your company, service providers, products, promotions, services or related things may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

4.7 E-signature software
To sign the Processor Controller agreement, we use software called esigngenie.com, based in USA so data concerning the GDPR contract may be transferred to USA. There is more about there security measure here: https://www.esigngenie.com/security and their privacy policy can be found here: https://www.esigngenie.com/privacy-policy.

5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data as follows:
All personal data about you, your company, service providers, products, promotions, services or related things that has been stored in our system will be kept for as long as you remain a user of our system. You can edit this data at any point in time and request a deletion by cancelling the usage of the system. Since we keep backups of all databases for up to 30 days, this data may still exist for up to 30 days on our servers at which point in time it gets deleted.

5.2 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject to such as accounting laws, or in order to protect your vital interests or the vital interests of another natural person.

6. Amendments

6.1 We may update this policy from time to time by publishing a new version on our website.

6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3 We may notify you of changes to this policy by email or through the private messaging system on our website.

7. Your rights

7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2 Your principal rights under data protection law are:

the right to access;
the right to rectification;
the right to erasure;
the right to restrict processing;
the right to object to processing;
the right to data portability;
the right to complain to a supervisory authority; and
the right to withdraw consent.

7.3 In the SimplyBook.me system there is 3 groups of personal data.

Company data, which under some circumstances can be personal data on the service provider if he is registered as the company.
Users, service providers data, which is data related to the people who provide services on behalf of the Company or Person registered as the company.
Clients, which are those who book services and buy items from the company and service providers.

7.4 Access to each of these information, and about each person related to each group is readily available inside the system for approved users. Data can be updated, deleted and exported in a constructed JSON format for data subjects who demand this.

7.5 Clients of system users also have readily available access to all their personal data either by login, or by link. If they want to delete their information, they need to contact the controller who has the necessary tools to do this.

8. About cookies

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

9. Cookies that we use

9.1 We use cookies for the following purposes:

(a) authentication - we use cookies to identify you when you visit our website and as you navigate our website;
(b) status - we use cookies to help us to determine if you are logged into our website;
(c) advertising - we use cookies to help us to display advertisements that will be relevant to you. cookies used for this purpose are: adroll, facebook, google adwords, adsense;
(d) analysis - we may use cookies to help us to analyse the use and performance of our website and services. cookies that may be used for this purpose are: hotjar (see more about Hotjar legal commitment here: https://www.hotjar.com/legal/compliance/gdpr-commitment), and Google Optimize, (see more about Google privacy policy here: https://policies.google.com/privacy);
(e) consent - we use cookies to store your preferences in relation to the use of cookies more generally.

10. Cookies used by our service providers

10.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

10.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy.

10.3 We use may use Adroll from time to time to display retargeting ads to visitors. This service uses cookies for tracking visitors so relevant ads can be published on sites you visit. You can view the privacy policy of Adroll here: http://www.adrollgroup.com/privacy.

10.4 We use Facebook ads to advertise relevant ads from us for visitors to our site. A cookie from Facebook is used to place ads from us on Facebook pages that you visit. Facebook's privacy policy is available at: https://www.facebook.com/legal/FB_Work_Privacy.

11. Managing cookies

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome)
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Mozilla Firefox)
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera)
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer)
(e) https://support.apple.com/kb/PH21411 (Safari)
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge)

11.2 Blocking all cookies will have a negative impact upon the usability of many websites.

11.3 If you block cookies, you will not be able to use all the features on our website.

12. Our details

12.1 This website is owned and operated by SimplyBook.me Ltd

12.2 The company is registered in Cyprus and our registered office is at 30, Gladstonos Street, P. Makedonas Court, Mezzanine Floor, 3041, Limassol, Cyprus.

12.3 You can contact us: