GDPR Compliance
Your data rights and how we protect them
Summary
- Your data is stored securely in EU-compliant data centers
- All data is encrypted in transit and at rest
- You have full control over your personal data
- You can request data deletion at any time
Your Rights Under GDPR
Right to Access
Request a copy of all personal data we hold about you.
Right to Rectification
Correct any inaccurate or incomplete personal data.
Right to Erasure
Request deletion of your personal data ("right to be forgotten").
Right to Portability
Receive your data in a portable format to transfer elsewhere.
Data Controller
Controller vs Processor — two distinct roles. WISE PEOPLE S.R.L. ("Primer") is the data CONTROLLER ONLY for personal data it processes for its own platform purposes — namely: account registration and authentication of salon owners and staff, billing of salon subscriptions, platform security and fraud prevention, aggregated and de-identified service analytics and improvement, and compliance with Primer's own legal obligations. For all personal data belonging to a salon's clients, website visitors and staff that a salon collects and manages through Primer (e.g. names, phone numbers, emails, appointment and service history, notes), the SALON is the data CONTROLLER and WISE PEOPLE S.R.L. acts solely as the salon's PROCESSOR, processing such data only on the salon's documented instructions under a Data Processing Agreement (GDPR Art. 28). Data-subject requests concerning a salon's client data should be addressed to the relevant salon as controller; Primer will assist the salon in responding.
WISE PEOPLE SRL
Calea Turzii 188 L, Et. 2, Ap. 13
Cluj-Napoca, Cluj, 400495, Romania
CUI: 48834175 | J12/4040/2023
Administrator: Mihaila Claudiu
Phone: +40 750 486 944
Data Protection Contact: privacy@primer.tech
Legal Basis for Processing
We process your data under the following legal bases:
- Contract:: To provide the services you've signed up for
- Consent:: For marketing communications (you can withdraw anytime)
- Legitimate Interest:: For service improvements and security
- Legal Obligation:: To comply with tax and regulatory requirements
Data Retention
We retain your personal data for as long as necessary to provide our services and comply with legal obligations. When you delete your account, we will delete your personal data within 30 days, except where we are required by law to retain it longer.
International Transfers
Your data is primarily stored in EU data centers. When we transfer data outside the EU (e.g., to service providers), we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.
Third-Party Processors
We use the following GDPR-compliant processors:
- Stripe: Payment processing (EU/US with SCCs)
- Vercel: Hosting infrastructure (EU regions available)
- Twilio: SMS and WhatsApp communications (Data Processing Agreement in place)
- Meta Platforms: WhatsApp Business messaging (Data Processing Agreement in place)
- Neon: Database hosting (EU regions)
How to Exercise Your Rights
To exercise any of your GDPR rights, you can:
- Email us at privacy@primer.tech
- Use the data export/delete features in your account settings
- Write to us at our registered address
We will respond to your request within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.
Supervisory Authority
Our lead supervisory authority is the Romanian National Authority for the Supervision of Personal Data Processing (ANSPDCP). You may also contact your local data protection authority if you are located in another EU member state.