Privacy Notice
At Lay Bare, we value your concerns about privacy and we want to make sure you feel comfortable using our websites and applications.
Introduction
Lay Bare Group of Companies (hereafter, “Lay Bare”) understands the importance of protecting your Personal Data. Our policy describes how we collect, protect, and manage information from you through our websites, information systems, and processes (forms and contracts), and other related systems. Lay Bare respects the confidentiality of Personal Data and is committed to comply with Republic Act No. 10173 or the Data Privacy Act of 2012. We value data privacy rights and herein ensure that all Personal Data collected from our customer, vendors, partners, employees, associates, and other stakeholders, are processed and stored in compliance to the general principles of transparency, for a legitimate purpose and proportionality.
This Privacy Policy explains the following:
- What information we collect and why we collect it
- How we use the said information and to whom we may disclose it
- The choices available for you to manage your personal information
- How we safeguard your Personal Data
By providing Lay Bare with your Personal Data in the use of any of our products and services as described in this Privacy Policy, you have explicitly authorized and consented to our collection, use, access, transfer, storage, and processing of said Personal Data.
Terms
The following terms are defined under the Data Privacy Act of 2012 as follows:
- “Personal Data” refers to all types of personal information
- “Personal Information” refers to any information, whether recorded in material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual
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“Sensitive personal information” refers to personal information:
- About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical, or political affiliations;
- About an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such individual, the disposal of such proceedings, or the sentence of any court in such proceedings;
- Issued by government agencies peculiar to an individual which includes, but is not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and
- Specifically established by an executive order or an act of Congress to be kept classified.
Personal Data And Other Information We Collect
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Consent
By buying/availing of our products and services, you may have provided your Personal Data to us. Your personal data may also be obtained passively by buying and availing our services and products. As such, your rights under this Privacy Policy shall be respected pursuant to the Data Privacy Act of 2012.
By providing your consent through our ‘consent document’ or a ‘Pre-Session Consent Form’, both from our branches and at our Lay Bare App, your data shall be processed and protected under the provisions of this policy.
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Personal Information
As part of our dealings with you, we may collect the following Personal Data when necessary, including but not limited to:
- Your name, gender, civil status, date of birth, address, telephone or mobile numbers, email address, mailing address, proof of identification and any other information relating to you which you have provided us in submission of any form as a result of our interaction with you.
- Your credit history, bank account, and credit card information that you provide us in submitting your franchise application.
- Your employment history, education background, resume, and income information when you apply for a job with us.
- Information about your visit and use of our websites, digital platforms, and mobile apps, including but not limited to social media profile information, IP Addresses, your browsing behavior within and throughout our digital assets, and session lengths, are collected by our website analytics tools and cookies that we may place on your computer. You may disable the use of cookies on your browser at any time.
- Your social media behavior when you tag, mention, or post photographs of us on any social media account (e.g. Facebook, Twitter, Instagram, LinkedIn, etc.)
- Your work-related information regarding your company, your ownership, and participation when you apply for vendor accreditation.
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Collecting And Storing Personal Data
We may collect and store your Personal Information under the following circumstances:
- When you purchase or avail of any of our products, services, promos, activities, and events.
- When you interact with any of our employees, through email, phone, chat services, or face-to-face meetings.
- When you submit information through any or all forms of our digital platforms (i.e. websites, apps), or connect with us through any of our social media accounts (e.g. Google, Facebook, Twitter, Instagram, LinkedIn, etc.)
- When you provide personal information in relation to inquiries, requests, and complaints.
- When you respond to surveys, promotions, and other marketing and sales initiatives.
- When you submit a job application.
- When we receive references from third parties or our business partners (i.e. when you have been referred by them).
- When you submit your personal data to us for any other reason.
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Personal Information Collection And Processed Through Third-Party Social Media Accounts.
Lay Bare may also collect your personal information when you use social media to use Lay Bare’s Services, interact with Lay Bare, or log-in through Lay Bare through your social media account.
For purposes of the same, Lay Bare may collect and process Personal Information such as:
- Your Name
- Your Email Address
- Any other additional information that you consent to sharing with Lay Bare
Should you choose to share this information with Lay Bare you are giving the company the permission to process, disclose, and retain the same in a manner consistent with Lay Bare’s Privacy Policy.
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Personal Information Collected And Processed Through The Lay Bare Application.
Lay Bare may also collect your personal information when you register, log-in, and use the Lay Bare Application.
For purposes of the same, Lay Bare may collection and process Personal Information such as:
- Your Name
- Your Email Address
- Your Mobile Number
- Your Log-In Credentials
- Information regarding your Location
- Information about your Device such as Brand, Type, MAC Address, etc.
- Your Activities within the Application
Lay Bare’s Access to Personal Information provided through the application may be enabled or disabled through your device settings.
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Personal Data Other Than Yours
When you disclose to us another person’s personal information (i.e. your dependent, spouse, children and/or parents’ information) you attest and warrant that consent has been duly obtained from that person to disclose and process personal information in accordance with this policy.
For purposes of the same, Lay Bare may collection and process Personal Information such as:
Use And Disclosure Of Personal Data
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Uses Of Your Personal Data
Lay Bare collects, uses, and discloses your Personal Information for the following purposes:
- To provide you with products and services that you have requested.
- To enhance your customer experience by delivering product services that match your preference and needs.
- To allow you to access the features of the services offered.
- To improve and customize your user experience.
- To communicate relevant information including responses to your queries, requests, and complaints.
- To store the same in Lay Bare’s services for its retention period.
- To provide you information about our products and services which may be of interest to you.
- To comply with the requirements of the law and legal proceedings such as court orders; comply with legal obligation, or to prevent imminent harm to public security safety or order.
- To prevent, detect, and investigate possible violation of Lay Bare rules and regulations, which may include violations of Philippine Law, and to manage and mitigate risks to prevent the same.
- To process information for statistical, analytical, and research purposes.
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Other Uses By Nature Of Our Dealings
Aside from the general uses mentioned previously, we may likewise use your personal data in any of the following instances depending on your dealings with us, in any of the following manner:
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WHEN YOU APPLY TO BECOME A FRANCHISEE
- To conduct appropriate due diligence checks.
- Register and process your application.
- To evaluate applications and to conduct corresponding background checks.
- To perform financial transactions such as the processing payments and perform other actions necessary.
- Any other purpose deemed necessary.
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WHEN YOU ARE A VENDOR, A PROSPECTIVE VENDOR, OR A CONTRACTOR
- To conduct appropriate due diligence checks.
- To evaluate proposals and to conduct corresponding background checks, if necessary.
- To assess your viability as a vendor and process your accreditation.
- To communicate with you about matters relating to our required products and services.
- Any other purpose deemed necessary.
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WHEN YOU APPLY FOR EMPLOYMENT OR BECOME OUR EMPLOYEE
- To process your application including any of the following:
- Conducting a background check.
- Conducting aptitude and personality tests and checks.
- Conduct of interviews.
- Facilitating medical check-ups and clearances.
- Collecting information about your suitability for the position.
- To administer benefits and payroll processing.
- To assess your performance.
- To perform other actions necessary or desirable in the implementation of your employment contract.
- Any other purpose deemed necessary.
- To process your application including any of the following:
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WHEN YOU APPLY TO BECOME A FRANCHISEE
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Disclosure Of Your Personal Data
Lay Bare will not intentionally disclose or transfer (and will take reasonable steps to prevent the unauthorized or accidental disclosure of) your personal data to third parties without your consent or as otherwise permitted by law, whether for such third parties’ own marketing purposes or otherwise, except as follows:
- We may disclose your personal data to the following as reasonably necessary, depending on the product or service concerned:
- Our Employees and Officers;
- Professional advisers such as lawyers and auditors;
- Insurers and credit providers;
- Banks, credit card companies and their respective service provider
- Suppliers or subcontractors, third party service providers, consultants to provide financial, technical, architectural, administrative services such as information technology, payroll, accounting, sales administration, procurement, training, and other services;
- Any third-party businesses offering goods and services or sponsor contests or other marketing and promotional programs.
- We may likewise disclose your personal information as reasonably necessary and for the purpose set out in this policy to any of the following:
- Members of our group of companies or our subsidiaries and affiliates;
- Customer Care Team
- Franchise Operations and Relation Department
- Human Capital Team
- Enterprise Innovation department
- Operation Team
- Compliance team
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Our joint venture and alliance partners;
- Consultants
- Members of our group of companies or our subsidiaries and affiliates;
- We may disclose your personal data:
- To the extent that we are required to do so by applicable law and/or rules and regulations;
- In connection with any ongoing or prospective legal proceedings;
- To the clients and/or customers availing of our products and services;
- To support auditing, compliance, and corporate governance functions;
- In so far as it is necessary for the protection of lawful rights and interests of natural or legal persons in court proceedings, or the establishment, exercise, or defense of legal claims, or when provided to government or public authority pursuant to a constitutional, statutory, or any legal mandate;
- Any company with which we share information about you for the above purposes is contractually required to comply with confidentiality standards, undertake to respect any individual's right to privacy and comply with the Data Privacy Act. We also require that these organizations use this information only for our purposes and follow our reasonable directions with respect to this information. This includes organizations, which handle or obtain Personal Information as service providers.
- We may disclose your personal data to the following as reasonably necessary, depending on the product or service concerned:
International Data Transfers
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Cloud Services
Information that we collect may be stored and processed in and transferred between any of the countries in which we make use of cloud services in order to enable us to use the information in accordance with this policy.
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Internet
Personal data that you publish on our website or submit for publication on our website may be available via the Internet, around the world. We cannot prevent the use or misuse of such information by others.
Retention and Disposal of your Personal Information
Lay Bare will retain personal data, as necessary, for the duration of Five (5) years from the expiry of our business relationship with you or any matter relating thereto which shall include, but is not limited to, legal proceedings, requirements of government agencies, or any other requirements set forth by law.
Thereafter your personal information shall be disposed of or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public. To know more, please refer to Lay Bare’s Data Retention and Disposal Policy.
Your Rights
Where granted by applicable law, you have the right to the following:
- Request reasonable access to the personal data that we have collected from you for the purposes of reviewing, modifying, or requesting deletion of the data.
- To request a copy of the personal data that we have collected from you and to have any inaccuracies in that data corrected.
- In certain circumstances, you may also request that we cease processing your personal data. If you wish to withdraw your consent given for any or all purposes set out in this policy, you may send your detailed request to dpo.lbwpi@lay-bare.com. Depending on the nature of your consent withdrawal, Lay Bare may not be in a position to pursue any future transactions with you.
To help protect your privacy and security, we will take reasonable steps to verify your identity, by, but not limited to requiring your Client ID before granting you access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Different laws may prevent us from providing you access to your personal data or otherwise fully accommodating your request depending upon the circumstances and the request, such as for example, where producing your information may reveal the identity of someone else.
We reserve the right to charge the appropriate fee for accommodating your request where allowed by applicable law. We likewise reserve the right to deny your requests where they may be manifestly unfounded, and/or excessive, impractical, or otherwise objectionable or unwarranted under applicable law.
Protecting your Information
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PROTECTING INFORMATION YOU SUBMIT ONLINE
We take precautions to protect your information. When you submit sensitive information via any of our official website(s), information is protected both online and offline. Wherever we collect sensitive information (such as credit card data), this is passed on through our payment gateway, which encrypts and transmits to us in a secure way. All our critical websites undergo security-scanning penetration testing to reduce our websites’ vulnerability against cyber security attacks. While we employ all necessary precautions to safeguard your information, the Internet is not 100% secure so we cannot guarantee that information we collect or store will be protected from all unauthorized access and thereby used in a manner that is not inconsistent with this Privacy Policy.
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HOW WE SAFEGUARD YOUR PERSONAL INFORMATION
We maintain physical, technical, and organizational safeguards to protect your personal data against loss, theft, unauthorized access, disclosure, copying, use or modification. We also put in effect safeguards such as:
- Using secured servers behind advanced threat protection appliances, firewalls, encryptions and other security tools.
- We limit access to your personal information to those who are qualified and authorized to process them. All such persons, wherever they are located, are required by us to protect the confidentiality and privacy of your personal data in a manner consistent with our privacy policies and practices.
- Our information system/infrastructure undergo regular security vulnerability and penetration testing to ensure your personal information is properly protected.
Third Party Websites
Our websites may contain hyperlinks and details of third-party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties. We therefore advise you to review their own privacy policy. Once you leave our website, you should check the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you.
Management and Security
A Data Privacy Officer for Lay Bare and corresponding Compliance Officers of Privacy for our subsidiaries have been appointed per affected subsidiaries to manage and safeguard the handling of your Personal Data compliant with the Data Privacy Act of 2012 and this Policy. We are committed to ensure that Lay Bare’s Privacy Management Program is constantly reviewed, monitored, and enhanced.
Our Data Protection Office
Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with the Data Privacy Act of 2012.
If you have any concerns or questions about our use of your personal data, you can contact our Data Privacy Team by writing to dpo.lbwpi@lay-bare.com.
Updates to the Policy
Lay Bare will amend this Privacy from time to time. We may also update this policy to apply changes due to new laws and regulation affecting the data privacy act changes in our business operations and environment. Any updates of changes will be posted on our website with a date stamped so that you are informed of the latest Policy update.
Privacy Policy
Lay Bare Group of Companies (in reference to Lay Bare Waxing Philippines and its sister companies and affiliates shall be collectively referred as "Lay Bare", "we", "us" or "our") understands the importance of protecting your Personal Data. Our policy describes how we collect, protect and manage information systems, and processes, and other related systems.
Why We Process Your Data
To keep you up to date with the latest content including promos, announcements, products, invitation and event launch. Manage any existing membership you have to us. Regulate your bookings, queries and feedback through our online surveys, etc. Use a variety of marketing channels to tap our existing contacts and ensure that they are well-informed.
Limitations
Personal data shall be collected for specified and legitimate purposes and not further that expected. Your personal data shall be processed lawfully, fairly and in a transparent manner in accordance with the data subject rights.
Integrity and Confidentiality
Your personal shall be processed with reasonable and appropriate organizational, physical and technical security measures to ensure protection of the data against unauthorized processing, accidental loss, alteration or damages.
Confidentiality Commitment
At Lay Bare, we value your privacy concerns and want to ensure you feel comfortable using our websites and applications.
We affirm our commitment to maintaining the confidentiality of the information we share. We understand the importance of safeguarding sensitive and proprietary information and assure you that all necessary measures are taken to preserve its privacy.
Confidentiality Obligation
We acknowledge that any information provided by you or obtained shall be treated as confidential. This includes but is not limited to:
- Personal Information, such as your name, gender, civil status, date of birth, address, telephone or mobile numbers, email address, mailing address, proof of identification, and any other information relating to you that you have provided us in the submission of any form as a result of our interaction with you.
- Sensitive Information such as race, ethnic origin, marital status, age, color, and religion, for diagnosis or treatment of your skin or aesthetic condition, quality improvement, coordination of care, training, and research.
- Information about your visit and use of our websites, digital platforms, and mobile apps, including but not limited to social media profile information, IP Addresses, your browsing behavior within and throughout our digital assets, and session lengths, are collected by our website analytics tools and cookies that we may place on your computer. You may turn off cookies on your browser at any time.
Non-Disclosure and Non-Use
We commit not to disclose, distribute or use any confidential information provided by you for any purpose unless we have obtained your prior written consent or as required by law. We will exercise due care and diligence in protecting confidentiality and preventing unauthorized access to the information.
Safeguarding Measures
We will implement appropriate technical, physical, and administrative measures to enhance confidential information's confidentiality, integrity, and security. These measures may include access controls, encryption firewalls, employee training, and other industry-standard security practices.
Third-Party Disclosure
We commit not to disclose, distribute or use any confidential information provided by you for any purpose unless we have obtained your prior written consent or as required by law. We will exercise due care and diligence in protecting confidentiality and preventing unauthorized access to the information.
Limitations
Lay Bare collects, uses, and discloses your Personal Information for the following purposes:
- To provide you with the products and services that you have requested.
- Enhance your customer experience by delivering product services matching your preference and needs.
- To allow you to access the features of the services offered.
- To improve and customize your user experience.
- To communicate relevant information, including responses to your queries, requests, and complaints.
- To store the same in Lay Bare’s services for its retention period.
- To provide you with information about our products and services which may interest you.
- To comply with the requirements of the law, legal proceedings such as court orders and comply with a legal obligation. Prevent imminent harm to public security safety or order.
- To prevent, detect, and investigate possible violations of Lay Bare rules and regulations, which may include violations of Philippine Law, and to manage and mitigate risks to prevent the same.
- To process information for statistical, analytical, and research purposes.
Integrity and Confidentiality
We take reasonable and suitable measures, both organizational and technical, to process your data to ensure its protection against unauthorized processing, accidental loss, alteration, or damage.
We understand that any breach of this confidentiality commitment may have severe legal and reputational consequences. Therefore, we assure you that we will exercise the highest care and responsibility in handling the confidential information entrusted to us.
If you have any questions or concerns regarding this confidentiality commitment or require further clarification, please do not hesitate to contact us.
Thank you for your trust in our brand and services. We look forward to serving you while upholding the principles of confidentiality and professionalism.
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