Privacy Policy

1. Who We Are

SMP By Lux is a brand operated by:

Luxmi Petticrew, sole trader, trading as Lux Aesthetic Studio

For the purposes of applicable data protection law, including the General Data Protection Regulation (GDPR) and the Data Protection Act 2018, Luxmi Petticrew trading as Lux Aesthetic Studio is the data controller responsible for personal data processed in connection with SMP By Lux.

SMP By Lux is the brand through which scalp micropigmentation services are promoted and provided.

2. Personal Information We May Collect

Depending on how you interact with SMP By Lux, we may collect information including:

• Your full name
• Email address
• Telephone number
• Preferred method of contact
• Treatment or service you are interested in
• Information included in your enquiry or communications with us
• Photographs that you choose to upload or send for consultation purposes
• Consultation and treatment information where you become a client
• Appointment and communication records
• Marketing preferences and consent
• Technical information associated with your use of the website, where applicable

You are not required to upload photographs when making an initial website enquiry.

3. Photographs and Information About Hair Loss

The SMP By Lux enquiry form allows you to voluntarily upload photographs to help Lux understand your hair-loss concerns and the type of SMP treatment you may be interested in.

These photographs may show your scalp, hair, face or other identifying features and may therefore constitute personal data.

You may also voluntarily provide information relating to hair loss, medical conditions, previous procedures, scarring, alopecia, medication or other health-related circumstances.

Where information you provide constitutes health data or another special category of personal data, it will be handled with additional care and processed only where an appropriate lawful basis and condition under applicable data protection law applies.

Where required, we may ask for your explicit consent to process health-related information for consultation or treatment purposes.

Please only provide information that is relevant to your enquiry or treatment.

4. Why We Use Your Personal Information

We may process your personal information to:

• Respond to enquiries
• Assess whether SMP may be suitable for your needs
• Review photographs submitted for consultation purposes
• Arrange and manage consultations
• Communicate with you about your enquiry or appointment
• Provide requested SMP services
• Maintain appropriate client and treatment records
• Provide pre-treatment and aftercare information
• Respond to questions or complaints
• Maintain the security and operation of our website
• Comply with legal, regulatory, insurance, accounting or professional obligations
• Send marketing communications where you have given appropriate consent

We will not use consultation photographs for advertising, social media, website results, promotional material or other marketing purposes simply because you submitted them as part of an enquiry.

Any separate use of identifiable client photographs for promotional or portfolio purposes will require an appropriate separate permission or consent process.

5. Our Lawful Bases for Processing

Depending on the circumstances, we may process personal data because:

• It is necessary to take steps at your request before entering into a contract
• It is necessary to perform a contract with you
• We have a legitimate interest in responding to enquiries, operating the business, maintaining appropriate records and protecting our services
• We are required to comply with a legal obligation
• You have provided consent for a particular purpose

Where we rely on consent, you may withdraw that consent at any time. Withdrawal of consent does not affect processing that was lawfully carried out before consent was withdrawn.

Where special-category personal data such as health information is processed, an additional condition permitted under Article 9 GDPR will also be required.

6. Marketing Communications

The website may give you the option to consent to receiving news, updates, offers or other marketing communications from SMP By Lux.

Marketing consent is optional and is separate from your consultation enquiry.

You do not need to agree to marketing in order to:

• Submit an enquiry
• Request a consultation
• Receive information about SMP
• Become a client

Where consent is relied upon for electronic marketing, we will only use your details for that purpose where you have actively chosen to receive those communications.

You can withdraw your marketing consent or object to direct marketing at any time by using any unsubscribe facility provided or by contacting:

info@smpbylux.com

Withdrawing from marketing will not affect treatment-related, appointment-related or other necessary service communications.

7. How We Receive Your Information

We may receive personal information:

• Directly through the SMP By Lux website
• Through the consultation/enquiry form
• By email
• By telephone
• Through WhatsApp where you choose to contact us that way
• During consultations or appointments
• Through subsequent communications relating to your treatment

Where you choose to communicate using a third-party service such as WhatsApp or a social-media platform, that provider may process information in accordance with its own privacy practices.

8. Who We May Share Information With

We do not sell your personal information.

Personal data may be shared where reasonably necessary with trusted service providers who help us operate the business or website, such as:

• Website and hosting providers
• Email providers
• IT and technical-support providers
• Professional advisers
• Accountants
• Insurers
• Other service providers necessary for business administration

Information may also be disclosed where required by law, regulation, legal proceedings or a competent authority.

Where third-party processors handle personal information on our behalf, appropriate data-protection safeguards will be used where required.

9. International Data Transfers

Some technology or communications providers may process personal information outside Ireland or the European Economic Area.

Where this occurs, we will take appropriate steps where required to ensure that personal information receives an appropriate level of protection in accordance with applicable data-protection law.

This may include relying on an adequacy decision, appropriate contractual safeguards or another legally permitted transfer mechanism.

10. How Long We Keep Your Information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and to meet applicable legal, insurance and business requirements.

As a general approach:

Enquiries that do not proceed to treatment:
Enquiry information and consultation photographs will normally be retained for up to 12 months after the last meaningful contact, unless there is a legitimate reason to retain them for longer or you request earlier deletion where applicable.

Client and treatment records:
Where you proceed with treatment, relevant consultation, treatment, consent, payment and associated records may be retained for up to 7 years after your last treatment or client interaction, where appropriate for legal, insurance, professional or record-keeping purposes.

Marketing information:
Marketing information will be retained while your marketing consent remains valid or until you unsubscribe, withdraw consent or object to marketing. We may retain a minimal suppression record where necessary to ensure that your opt-out continues to be respected.

Some information may need to be retained for longer where required by law, an insurance requirement, a legal claim or another legitimate reason.

Information that is no longer required will be securely deleted, anonymised or otherwise disposed of appropriately.

11. How We Protect Your Information

Reasonable technical and organisational measures are used to protect personal information against:

• Unauthorised access
• Accidental loss
• Misuse
• Alteration
• Disclosure
• Destruction

The website enquiry system is designed so that photographs uploaded through the consultation form are not intentionally stored in a publicly accessible website directory.

However, no internet transmission or electronic storage system can be guaranteed to be completely secure.

12. Cookies and Similar Technologies

The SMP By Lux website may use cookies or similar technologies that are necessary for the operation and security of the website.

If analytics, advertising, Meta Pixel or other non-essential tracking technologies are introduced, appropriate information and consent controls will be provided where required.

Further information will be available in our Cookie Policy.

13. Your Data Protection Rights

Subject to the circumstances and applicable law, you may have the right to:

• Request access to personal information held about you
• Request correction of inaccurate or incomplete information
• Request deletion of your personal information
• Request restriction of processing
• Object to certain processing
• Object at any time to processing for direct-marketing purposes
• Request data portability where applicable
• Withdraw consent where processing is based on consent
• Lodge a complaint with the Data Protection Commission

Some rights are not absolute and may depend on the circumstances and the lawful basis on which information is being processed.

14. Exercising Your Rights

To exercise your data-protection rights or ask a question about how your information is handled, contact:

We may need to verify your identity before responding to certain requests.

15. Complaints

If you have concerns about how your personal information has been handled, please contact us first so that we have an opportunity to address your concerns.

You also have the right to make a complaint to the Irish Data Protection Commission (DPC).

16. Third-Party Websites

The SMP By Lux website may contain links to third-party websites or services, including social-media platforms, mapping services and communications providers.

We are not responsible for the privacy practices of independent third-party websites. You should review their privacy information when using those services.

17. Changes to This Privacy Policy

This Privacy Policy may be updated periodically to reflect changes to our services, website, technology, legal obligations or the way personal information is processed.

The latest version will always be published on the SMP By Lux website with the date of the most recent update.