Privacy
Privacy Policy
Last updated: [PUBLICATION DATE]
This Privacy Policy describes how the personal data of visitors and clients of the NAGI Japanese Head Spa website is processed, in accordance with Regulation (EU) 2016/679 (GDPR) and applicable Portuguese law.
1. Data controller
The data controller is [LEGAL ENTITY NAME], with address at [FULL ADDRESS], Cascais, Portugal.
Contact for privacy matters: [PRIVACY EMAIL].
2. Personal data we collect
- Contact and booking data you voluntarily provide when contacting us (for example, via WhatsApp): name, phone number and the content of your messages.
- Details of the requested appointment (service, preferred date/time).
- Browsing and device data collected through cookies and similar technologies — only when authorised by you (see the Cookie Policy).
We do not collect special categories of data. We do not request health data; if you share information relevant to the session, you do so on your own initiative and on the basis of your consent.
3. Purposes and legal bases
| Purpose | Data | Legal basis (GDPR) |
|---|---|---|
| Respond to enquiries and handle bookings | Name, phone, message, service | Pre-contractual steps at the data subject's request (Art. 6(1)(b)) |
| Client communication and follow-up | Contact data | Legitimate interest (Art. 6(1)(f)) or consent (Art. 6(1)(a)) |
| Measuring and analysing site usage | Browsing data (cookies) | Consent (Art. 6(1)(a)) |
| Advertising and campaign measurement | Browsing data and identifiers (cookies) | Consent (Art. 6(1)(a)) |
| Compliance with legal obligations (e.g. tax) | Billing data, where applicable | Legal obligation (Art. 6(1)(c)) |
Consent for analytics and advertising is optional and may be withdrawn at any time, without affecting the lawfulness of prior processing or your access to essential services.
4. Communication via WhatsApp
The site's primary conversion happens via WhatsApp. When you contact us through it, your data is also processed by Meta Platforms Ireland Ltd., under WhatsApp's policies. We use WhatsApp solely to answer your request and arrange your appointment.
5. Analytics and advertising tools
The site is prepared to use analytics (Google Analytics 4) and advertising tools (Google Ads, Meta Pixel), which load only after your consent. These tools may use cookies and identifiers. Until they are configured and consent is given, they are not activated. See the Cookie Policy.
6. Recipients and processors
- Website hosting provider: [HOSTING PROVIDER].
- Meta Platforms Ireland Ltd. (WhatsApp and, if enabled, Meta Pixel).
- Google Ireland Ltd. (if enabled: Google Analytics, Google Tag Manager, Google Ads).
These providers act as processors or controllers, as applicable, and only process data as necessary for the stated purposes.
7. International transfers
Some tools (Google, Meta) may involve transfers of data outside the European Economic Area, notably to the United States. Such transfers rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses and/or the EU-US Data Privacy Framework. [TO BE CONFIRMED depending on the tools actually enabled.]
8. Retention periods
- Enquiries without a booking: kept for [RETENTION PERIOD, e.g. 12 months].
- Client data with a booking: for the period needed to provide the service and applicable legal periods.
- Tax/accounting obligations: for the periods required by law.
- Cookie data: as indicated in the Cookie Policy.
9. Your rights
As a data subject, you have the right of access, rectification, erasure, restriction of processing, portability and objection, as well as the right to withdraw consent at any time.
To exercise these rights, contact us at [PRIVACY EMAIL]. You may also lodge a complaint with the Portuguese Data Protection Authority (CNPD) — www.cnpd.pt.
10. Automated decisions
We do not carry out automated individual decision-making, including profiling, producing legal or similarly significant effects on you. [TO BE CONFIRMED if advertising profiling features are later enabled.]
11. Cookies
The use of cookies and similar technologies is described in detail in the Cookie Policy, where you can also manage your preferences.
12. Changes to this policy
This policy may be updated whenever necessary. The version in force is the one published on this page, showing the date of the last update.