Privacy Notice

1.1 Definition of Parlon

“Parlon,” “we,” “us,” or “our” refers to:

• Parlon Beauty and Wellness Technologies, Inc. (Philippines);
• Parlon Pte. Ltd. (Singapore); and
• their respective affiliates and local operating entities, where applicable.

1.2 Nature of the Business

Parlon operates a global technology platform that enables individuals to discover, book, and purchase beauty and wellness services offered by independent third-party service providers (“Merchant Partners”), and provides software-as-a-service tools to such Merchant Partners.

Parlon does not itself provide beauty or wellness services.

This Notice applies to you if you:

• 2.1 visit or browse the Platform;
• 2.2 create an account or transact as a customer or user;
• 2.3 purchase gift codes, vouchers, or subscriptions through the Platform;
• 2.4 work for or represent a Merchant Partner (e.g. owner, administrator, staff);
• 2.5 communicate or engage with Parlon; or
• 2.6 interact with Parlon in connection with analytics, advertising, partnerships, or research.

3.1 Parlon as Independent Personal Data Controller

Parlon acts as an independent Personal Data Controller when it processes Personal Data for its own legitimate business purposes, including to:

• 3.1.1 operate, secure, and improve the Platform;
• 3.1.2 enable discovery, bookings, purchases, subscriptions, and account management;
• 3.1.3 facilitate payments (without storing card details);
• 3.1.4 conduct analytics, reporting, market studies, and advertising measurement;
• 3.1.5 prevent fraud, abuse, and security incidents;
• 3.1.6 comply with legal, regulatory, and contractual obligations; and
• 3.1.7 support corporate governance and business continuity.

3.2 Merchant Partners as Independent Controllers

Merchant Partners are independent Personal Data Controllers in respect of all Personal Data relating to Customers, Contacts, Redeemers, or other individuals that they collect, input, access, use, store, disclose, or otherwise process in connection with their services, whether directly or through the Platform.

Merchant Partners determine the purposes and means of such processing and are solely responsible for compliance with applicable data protection and privacy laws.

Parlon does not control, supervise, or endorse how Merchant Partners process Personal Data and does not assume responsibility or liability for their independent processing activities.

3.3 Parlon as Personal Data Processor (Limited Context)

To the extent Parlon processes Personal Data solely on behalf of a Merchant Partner to provide software-as-a-service infrastructure, Parlon acts as a Personal Data Processor, subject to applicable law and contractual arrangements.

4.1

To the maximum extent permitted by law, Parlon shall not be liable for any unauthorized, unlawful, negligent, or improper processing of Personal Data by a Merchant Partner or its personnel, including failures to obtain consent, establish a lawful basis, honor data subject rights, or secure Personal Data.

4.2

Merchant Partners’ data protection obligations, warranties, and liabilities are governed by and expressly incorporated by reference to the Parlon Terms of Service, including provisions on data protection, compliance, and indemnification.

5.1 Information You Provide

Depending on how you use the Platform, Parlon may collect:

• 5.1.1 name, email address, and mobile number;
• 5.1.2 account credentials and profile details;
• 5.1.3 date of birth, for eligibility verification, age-appropriate access, fraud prevention, account management, and, where permitted by law and subject to your marketing preferences, sending birthday greetings or promotional offers;
• 5.1.4 booking, purchase, and redemption information;
• 5.1.5 service preferences and settings;
• 5.1.6 delivery or service location (if applicable);
• 5.1.7 communications and support requests;
• 5.1.8 content you upload (e.g. photos, reviews); and
• 5.1.9 other information you choose to provide.

Date of birth is treated as personal data (not sensitive personal information) and is subject to appropriate security and access controls.

5.2 Payments

• 5.2.1 Payment information is processed directly by third-party payment processors.
• 5.2.2 Parlon does not store full payment card details.
• 5.2.3 In limited circumstances (such as processing refunds), Parlon may collect bank account or similar financial details, which are treated as sensitive or high-risk personal data, collected only when strictly necessary, used solely for the relevant transaction, protected by enhanced security measures, and retained only for as long as required by law or operational necessity.

5.3 Automatically Collected Data

Parlon may automatically collect:

• 5.3.1 IP address and device identifiers;
• 5.3.2 browser, operating system, and app version;
• 5.3.3 usage, interaction, and clickstream data;
• 5.3.4 approximate location (country or region); and
• 5.3.5 cookies and similar technologies.

Parlon processes Personal Data to:

• 6.1 provide and operate the Platform and Services;
• 6.2 facilitate bookings, purchases, subscriptions, and redemptions;
• 6.3 communicate with users, merchants, and partners;
• 6.4 provide customer and merchant support;
• 6.5 conduct analytics, reporting, research, and insights;
• 6.6 personalize content and improve user experience;
• 6.7 measure advertising and campaign effectiveness;
• 6.8 prevent fraud and ensure platform security;
• 6.9 comply with legal and regulatory obligations; and
• 6.10 support mergers, acquisitions, and corporate transactions.

Where required under applicable law, Parlon relies on one or more of the following lawful bases:

• 7.1 performance of a contract;
• 7.2 legitimate interests, provided such interests are not overridden by your rights;
• 7.3 compliance with legal obligations;
• 7.4 consent, where required by law; and
• 7.5 protection of vital interests, where applicable.

8.1

Parlon may use analytics, segmentation, and limited profiling tools to understand how the Platform is used, improve Services, and deliver relevant content, recommendations, offers, or communications.

8.2

This may include creating insights and segments based on activity and usage patterns, such as preferences inferred from bookings, purchases, redemptions, searches, and engagement (e.g. interest in hair coloring, facials, massages, or other beauty and wellness service categories).

8.3

Where practicable, Parlon uses aggregated, anonymized, or de-identified data for analytics, reporting, and market studies.

8.4

Any profiling does not produce legal or similarly significant effects on individuals.

9.1 Financial Information

Bank account or similar financial details collected for refunds or payment resolution are processed only when necessary, for limited purposes, and with enhanced security controls.

9.2 Health or Special Category Information

9.2.1 Merchant Partners may request or process health-related or other sensitive information (e.g. pregnancy status, allergies, medical conditions) as part of consultations or service delivery.

9.2.2 In such cases, the Merchant Partner acts as the independent Personal Data Controller.

9.2.3 Parlon does not determine the purpose or manner of such processing and, if involved, acts only as a technical service provider.

9.3

Parlon does not use sensitive personal data for profiling, advertising, or marketing purposes.

Parlon may share Personal Data with:

• 10.1 Merchant Partners you transact with;
• 10.2 payment processors and financial service providers;
• 10.3 cloud hosting and infrastructure providers;
• 10.4 analytics, marketing, and advertising partners;
• 10.5 professional advisers and auditors; and
• 10.6 regulators, courts, or authorities where required by law.

Parlon does not sell Personal Data as a standalone asset.

11.1 Parlon operates globally.

11.2 Personal Data may be transferred to and processed in jurisdictions outside your country, including Singapore and other locations where Parlon or its service providers operate.

11.3 Appropriate safeguards are implemented in accordance with applicable data protection laws.

12.1 Personal Data is retained only for as long as necessary to fulfill the purposes described in this Notice, unless a longer retention period is required or permitted by law.

12.2 Aggregated or anonymized data may be retained for longer periods.

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

• 13.1 access your Personal Data;
• 13.2 correct or update inaccurate data;
• 13.3 object to or restrict processing;
• 13.4 request deletion or data portability;
• 13.5 withdraw consent (where applicable); and
• 13.6 lodge a complaint with a data protection authority.

Parlon implements reasonable administrative, technical, and organizational measures to protect Personal Data against unauthorized access, loss, misuse, or disclosure.

Personal Data may be transferred as part of a merger, acquisition, restructuring, or sale of assets, subject to applicable law and this Notice.

Parlon may update this Privacy Notice from time to time. We will notify you of any material changes by posting the new Privacy Notice on this page and updating the “Last Updated” date.

Data Protection Officer

privacy@parlon.ph