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Privacy Policy

Data Controller

PHOAM GROUP LTD (trading as ‘PHOAM Hair’) is the data controller for the personal information collected through this website. This means we are responsible for deciding how we hold and use your personal data.

We are committed to protecting the privacy and security of our website visitors and customers. We hold your data securely and ensure that your rights as a data subject are respected.

We do not market our products to anyone under 16 years of age. We cannot identify individuals who are under 16 within our database.

What This Privacy Policy Covers

This Privacy Policy explains how PHOAM GROUP LTD (trading as ‘PHOAM Hair’) collects, uses, stores, and protects your personal data when you:

• Visit our website
• Create an account
• Make a purchase
• Sign up for marketing communications
• Enter competitions or promotions
• Contact our customer service team
• Use any applications or features on our website


The data we collect is used to:

• Process and fulfill your orders
• Process payments
• Ship your purchases
• Deliver marketing communications (with your consent)
• Personalize your experience on our website
• Provide customer support
• Improve our products and services

Legal Basis for Processing Your Data

We must have a valid legal reason to use your personal data. We process your data based on:

1. Contract Performance - To fulfill our obligations when you place an order

2. Legal Obligation - To comply with laws and regulations (e.g., tax, accounting)

3. Consent - When you give us permission (e.g., marketing emails, SMS)

4. Legitimate Business Interests - To improve our services, prevent fraud, and maintain security

Your Rights

If you have concerns about how we handle your data, you have the right to make a complaint to your local data protection authority:

• UK: Information Commissioner's Office (ICO) - www.ico.org.uk
• EU: Your national data protection authority
• US: Federal Trade Commission (FTC) - www.ftc.gov

However, we would appreciate the opportunity to address your concerns directly before you contact a regulatory authority. Please contact us at contact@phoamhair.com

Keeping Your Information Accurate

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us by updating your account details or contacting us directly.

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required by law.
Retention periods vary depending on:

• The type of data
• The purpose for which it was collected
• Legal or regulatory requirements

After the retention period expires, your data will be permanently deleted or anonymized. This action cannot be undone.

Types of Data We Collect & How We Use It

1. Identity & Contact Data

What we collect:
• Full name
• Email address
• Postal address
• Phone number
• Date of birth (optional)

Why we collect it:
• To create and manage your account
• To verify you meet age requirements
• To process and deliver your orders
• To send order status updates
• To provide customer support
• To send marketing communications (if you've opted in)

Legal basis: Contract performance, consent (for marketing), legitimate interests

2. Order & Transaction Data

What we collect:
• Order history
• Products purchased
• Payment information (processed securely by our payment providers)
• Delivery details
• Returns and refunds

Why we collect it:
• To fulfill your orders
• To process payments securely
• To handle returns and refunds
• To prevent fraud
• To maintain financial records

Legal basis: Contract performance, legal obligation

3. Communication History

What we collect:
• Records of phone calls, emails, live chat conversations
• Social media interactions
• Customer service inquiries

Why we collect it:
• To provide effective customer support
• To respond to your questions and concerns
• To train our staff and improve service quality
• To resolve disputes

Legal basis: Legitimate interests, contract performance


4. Browsing & Purchase History

What we collect:
• Previous orders
• Browsing history on our website
• Products viewed or saved
• Items in your basket
• Wish list items

Why we collect it:
• To provide personalized recommendations
• To show relevant products and offers
• To improve your shopping experience
• To display targeted advertising on third-party platforms
• To process returns and provide support

Legal basis: Consent (for marketing), legitimate interests


5. Technical & Device Data

What we collect:

• IP address
• Browser type and version
• Operating system
• Device type
• Cookies and similar technologies
• Time zone settings
• Location data (approximate)

Why we collect it:
• To ensure our website functions properly
• To personalize your experience
• To remember your preferences and login details
• To improve website performance and security
• To analyze how visitors use our site
• To detect and prevent fraud

Legal basis: Legitimate interests, consent (for cookies)


6. Marketing & Communications Preferences

What we collect:

• Your preferences for receiving marketing
• Communication channel preferences (email, SMS, post)
• Interests and product preferences

Why we collect it:
• To send you relevant offers and promotions
• To respect your communication preferences
• To comply with marketing regulations
Legal basis: Consent
You can withdraw consent at any time by:
• Clicking "unsubscribe" in emails
• Texting STOP for SMS messages
• Updating preferences in your account
• Contacting us at contact@phoamhair.com


7. Competition & Survey Data

What we collect:

• Name, email, and contact details
• Responses to surveys
• Entries to competitions
• Event inquiries

Why we collect it:
• To administer competitions and select winners
• To improve our products and services
• To respond to event inquiries
• To understand customer preferences

Legal basis: Contract performance (for competitions), consent, legitimate interests

Anonymised & Aggregated Data

We also anonymize and aggregate personal data (so it no longer identifies you) for purposes including:

• Testing IT systems
• Research and data analysis
• Improving our website
• Developing new products and features
• Sharing industry insights with third parties

This anonymized data cannot be traced back to you individually.

Cookies & Tracking Technologies

We use cookies and similar technologies to enhance your browsing experience. For detailed information about the cookies we use and how to manage them, please see our Cookie Policy.

Data Sharing

We do not sell your personal data to third parties.

We may share your personal data with the following categories of organizations as necessary to provide our services:

Service Providers

• Payment processors - To securely process your payments
• Shipping & logistics companies - To deliver your orders
• Website hosting providers - To maintain our website
• Email service providers - To send order confirmations and marketing emails
• Marketing agencies - To manage advertising campaigns
• Customer service platforms - To provide support


Advertising Partners

We work with advertising partners such as:

• Google Ads
• Facebook/Meta

These partners may collect information about your interactions with our website and ads for personalization and analytics purposes. For more information about their data practices, please see their privacy policies.


Professional Advisors

• Legal advisors
• Accountants and auditors
• Insurers
• Bankers

Regulatory & Legal Authorities

• Tax authorities (e.g., HMRC, IRS)
• Law enforcement
• Regulatory bodies
• Courts


We may also share your data if we sell or transfer any part of our business or assets.


All third parties are required to:

• Keep your data secure
• Use it only for specified purposes
• Comply with data protection laws

Data Security

We have implemented appropriate security measures to protect your personal data from:

• Accidental loss
• Unauthorized access or use
• Alteration
• Disclosure

Security measures include:

• Encryption of sensitive data
• Secure server infrastructure
• Access controls and authentication
• Regular security assessments
• Staff training on data protection


Access to your personal data is limited to employees, agents, and contractors who have a legitimate business need. They are bound by confidentiality obligations and will only process your data according to our instructions.

In the event of a data breach that poses a risk to your rights, we will notify you and the relevant supervisory authority as required by law.

Your Data Protection Rights

Under data protection law, you have the following rights:

1. Right to Access
Request a copy of the personal data we hold about you.

2. Right to Rectification
Request correction of inaccurate or incomplete data.

3. Right to Erasure (Right to be Forgotten)

Request deletion of your personal data in certain circumstances.

4. Right to Restrict Processing
Request that we limit how we use your data.

5. Right to Data Portability
Request transfer of your data to another organization in a structured, commonly used format.

6. Right to Object
Object to processing based on legitimate interests or for direct marketing purposes.

7. Right to Withdraw Consent
Withdraw consent for marketing or other processing based on consent at any time.

8. Rights Related to Automated Decision-Making
We use your data to provide personalized recommendations and tailored shopping experiences. We do not use automated decision-making that would have a legally significant or similarly significant effect on you.


To exercise any of these rights, please contact us at contact@phoamhair.com


We may need to verify your identity before responding to your request. We will respond within one month of receiving your request.

Advertising & Analytics Partners

Google Analytics

We use Google Analytics to understand how visitors use our website. Google Analytics collects information anonymously and reports website trends without identifying individual visitors.

Learn more: Google Privacy Policy


Facebook Pixel

We use Facebook Pixel to measure advertising effectiveness and show you relevant ads on Facebook and Instagram.

Learn more: Facebook Data Policy

Mobile/SMS Marketing

Our SMS messaging service is operated by PHOAM GROUP LTD (trading as ‘PHOAM Hair’). By opting in, you agree to receive text messages including:

• Order updates and shipping notifications
• Account alerts
• Promotional offers (if you've opted in)


Important Information:

• Message frequency varies
• Standard message and data rates may apply
• Participation is completely voluntary
• Not required to make purchases
• Opt out anytime by texting STOP
• Text HELP for assistance or email contact@phoamhair.com


We may change our SMS numbers with advance notice. We are not liable for delayed, failed, or misdirected messages.

You agree to provide a valid mobile number and update it if it changes.

Children's Privacy

We may update this Privacy Policy from time to time to reflect changes in:

• Our data practices
• Legal or regulatory requirements
• Our business operations


We will notify you of significant changes by:

• Posting the updated policy on our website
• Updating the "Effective Date" at the top
• Sending you an email (for material changes)


We encourage you to review this Privacy Policy periodically.

Last Updated: 04/12/2025

Contact Us

If you have questions about this Privacy Policy or how we handle your personal data, please contact us:

Email: contact@phoamhair.com

CONSENT

By using our website and providing your personal data, you consent to the collection, use, and sharing of your information as described in this Privacy Policy.