Privacy Policy

1. SCOPE AND APPLICABILITY

This Privacy Policy applies to visitors to our website, barber shop owners and enterprise clients (“Shop Partners”), individual barbers and stylists (“Barbers”), and end-clients or customers booking appointments or purchasing services through our platform (“Clients”).

Depending on the context, Cortigo acts as an independent data controller regarding platform account management and direct user relationships, and as a data processor or service provider when processing appointment, client, and transaction data strictly on behalf of our Shop Partners.

2. INFORMATION WE COLLECT

We collect personal information directly from you, from Shop Partners and Barbers, and from third-party integrations.

• Information You Provide:
  • Account & Contact Details: Name, email address, phone number, and physical salon or shop addresses.
  • Professional & Business Data (Barbers & Shops): Business registration details, booth rental or employment status, schedule availability, service menus, pricing, and payout information.
  • Booking & Client Data: Appointment dates, service history, preferred barbers, notes or service preferences, and feedback.
  • Payment Information: Payment card details, billing addresses, and transaction histories processed securely via third-party payment gateways (e.g., Stripe).
  • Communications: Customer service inquiries, in-app messages, and SMS or email appointment confirmations.
• Information Collected Automatically:
  • Device & Technical Data: IP address, device identifiers, operating system, and browser type.
  • Usage Data: Pages visited, booking flow interactions, time spent, and referral URLs.
  • Location Data: General or precise geolocation data (with your permission) to help Clients discover nearby barber
    shops.
• Information from Third Parties: Third-party appointment calendars, social media sign-ins, and point-of-sale (POS)
  integration partners.

3. HOW WE USE INFORMATION

We use personal information to:

• Facilitate, confirm, and manage appointment scheduling between Clients and Barbers or Shop Partners.
• Process payments, tips, booth rentals, and merchant payouts.
• Send transactional notices, reminders, schedule changes, and promotional messages (where consented to) via SMS, push
  notifications, or email.
• Provide Shop Partners with analytics, client relationship management (CRM) features, and operational reporting.
• Improve platform functionality, troubleshoot technical issues, and develop new features.
• Detect, investigate, and prevent fraudulent transactions, unauthorized access, and chargeback disputes.
• Comply with applicable legal, tax, and accounting obligations.

4. LEGAL BASES FOR PROCESSING (GDPR / INTERNATIONAL)

Where applicable under international data protection laws, we process personal information under the following legal grounds:

• Performance of a Contract: To fulfill booking requests, manage merchant accounts, and process payment transactions.
• Consent: For marketing communications or location tracking, which can be withdrawn at any time.
• Legitimate Interests: To protect against fraud, analyze service performance, and improve user workflows, balanced
  against individual privacy rights.
• Legal Obligation: For tax, accounting, financial reporting, and compliance requirements.

5. AUTOMATED TOOLS AND ANALYTICS

Cortigo may use automated algorithms and analytics tools to assist with:

• Dynamic schedule optimization, smart re-booking reminders, and calendar conflict resolution.
• Client retention modeling, demand forecasting, and performance analytics for Shop Partners.
• Fraud detection during payment checkout and account onboarding.

Cortigo does not make fully automated decisions that produce legal or similarly significant effects concerning users without human intervention.

6. DISCLOSURE OF INFORMATION

We share personal information under the following conditions:

• Between Clients, Barbers, and Shop Partners: When an appointment is scheduled, relevant booking details, contact
  information, and service preferences are shared to enable fulfillment of the service.
• To Service Providers: With trusted third-party vendors who support operational services, including payment processors,
  SMS/telecom gateways, cloud hosting providers, and customer support tooling. All providers are bound by strict
  confidentiality and data protection obligations.
• Legal Compliance: When required by subpoena, search warrant, court order, or applicable regulatory mandates.
• Business Transfers: In connection with a corporate sale, merger, reorganization, acquisition, or asset transfer.
• No Sale of Personal Data: We do not sell personal information or client booking records for monetary consideration.

7. DATA RETENTION

We retain personal information for as long as your account remains active or as needed to provide booking and SaaS services to you and our Shop Partners. We also retain records as necessary to comply with financial, tax, and legal obligations, resolve disputes, and enforce our agreements. Retention periods vary based on data category and regulatory obligations.

8. DATA SECURITY

We implement commercially reasonable administrative, physical, and technical safeguards to protect personal data against loss, misuse, and unauthorized access. These measures include encrypted data transit (TLS/SSL), encryption at rest, role- based access restrictions, and continuous system monitoring. Payment transactions are handled in compliance with PCI- DSS standards via certified payment processing partners.

9. YOUR PRIVACY RIGHTS

• U.S. Privacy Rights (CCPA/CPRA and others): Depending on your state of residence, you may have the right to request access to personal data, request deletion, correct inaccurate details, or opt out of targeted advertising.
• EEA/UK/International Users: Individuals in the EEA or UK have rights under the GDPR, including access, correction, deletion, data portability, and the right to object to or restrict specific processing activities.
• Marketing & SMS Opt-Out: You may opt out of marketing communications via the unsubscribe link in emails or by replying "STOP" to SMS notifications.

10. COOKIES AND TRACKING TECHNOLOGIES

We utilize cookies, local storage, and similar web tracking mechanisms to manage login sessions, retain booking preferences, analyze traffic trends, and optimize user experience. Users may configure their browser settings or cookie management tools to decline non-essential cookies.

11. CHILDREN’S PRIVACY

Our Services are not directed to individuals under 16 (or under 18 depending on local jurisdiction), and we do not knowingly collect personal information directly from children. When a minor receives barbering services, booking details must be provided and authorized by a parent or legal guardian.

12. UPDATES TO THIS POLICY

We may update this Privacy Policy periodically to reflect operational, legal, or product adjustments. When changes are made, the “Last Updated” date will be revised, and material updates may be communicated through the Services or by email. Continued use of the Services constitutes acceptance of the updated terms.

13. CONTACT INFORMATION

If you have questions regarding this Privacy Policy, wish to exercise your data protection rights, or need general support, please contact us:

Clipper Connect LLC d/b/a Cortigo
Address: [Insert Business Address]
Email: privacy@cortigo.com