Privacy Policy
This policy explains how VELOURA BEAUTY COSMETICS LIMITED handles personal data when you enquire about or take part in an online curl coaching programme, including the photographs and video of your hair that the assessment depends on.
Last updated 13 September 2026
1. Who we are
VELOURA BEAUTY COSMETICS LIMITED is the data controller for the personal data described in this policy. We provide online curl coaching only: remote assessment of curl pattern, a written care routine and guided support. We do not run a salon and we do not sell products.
- Company: VELOURA BEAUTY COSMETICS LIMITED, registered in England and Wales, company number 17094629.
- Registered address: 16 Frodsham Drive, St. Helens, England, WA11 9BL, United Kingdom.
- Email: [email protected]
- Telephone: +44 7481 236094
We process personal data in accordance with the UK General Data Protection Regulation and the Data Protection Act 2018.
2. Data we collect
When you enquire
The enquiry form on our website opens your own email client and sends nothing to our servers. When you send that email we receive your name, email address, telephone number, the programme you are interested in and whatever you write in the message.
When you take part in a programme
- Contact details: name, email address and telephone number.
- Questionnaire answers: how often you wash your hair, what you currently use, how you dry and style it, and your colouring or lightening history.
- Photographs and video of your hair, dry and wet, as described in the next section.
- Session records: the written assessment we prepare for you, notes on adjustments agreed during the programme, and our correspondence with you.
- Payment records: the amount, the date and the reference. Card details are handled by our payment provider and are never seen or stored by us.
If you subscribe to curl notes
Only the email address you give us, kept until you unsubscribe.
3. Photographs and video of your hair
The assessment cannot be done without images, so this is the most sensitive material we hold. The following applies to every photograph and every video you send us.
- Your images are used for one purpose only: assessing your hair and preparing and adjusting your routine.
- They are never published, never used on our website or social media, never used in advertising or any other marketing, and never shown to anyone outside the coaching team working on your programme.
- They are never sold, licensed or shared with third parties for their own purposes.
- They are not used to train any automated or machine learning system.
- Your face may appear in the frame. You are welcome to crop or blur it before sending; the assessment works from hair, not from faces.
If we ever ask to show your images
Any public use, such as a before and after example, requires your separate, specific and written consent, given in advance for that particular use. It is never a condition of the service, it is never bundled into our terms, and you can refuse without any effect on your programme. We keep a record of any consent you give so that we can show what you agreed to, and you may withdraw it at any time by emailing us.
Deleting your images
You can ask us to delete your photographs and video at any point, including during the programme, and we will do so within thirty days. If you ask us to delete them while a programme is running, we will explain what part of the coaching we can no longer provide, but the deletion still goes ahead.
4. Purposes and legal bases
| What we do | Legal basis |
|---|---|
| Replying to your enquiry and agreeing a programme | Steps taken at your request before entering a contract |
| Assessing your hair from photographs, video and questionnaire answers | Performance of our contract with you |
| Preparing your written routine and running coaching sessions | Performance of our contract with you |
| Keeping session records so later adjustments make sense | Performance of our contract with you |
| Any public use of your images | Your separate explicit consent, given in writing in advance |
| Sending curl notes by email | Your consent, withdrawable at any time |
| Keeping our records secure and preventing misuse | Our legitimate interests in running the service safely |
| Keeping accounting and tax records | Compliance with a legal obligation |
5. Health data
We do not ask for and do not want information about your health. Curl coaching is cosmetic hair care: we do not diagnose or treat scalp conditions, hair loss or any other medical matter. If you mention a health matter to us anyway, we will not record it in your file beyond noting that we suggested you speak to your GP or a dermatologist.
6. Sharing with others
We do not sell personal data. We share it only with the following categories of recipient, and only as far as each needs it:
- Email and file storage providers that host our correspondence and the material you send.
- The video call platform used for live sessions.
- Our payment provider, for taking payment and issuing receipts.
- Our accountant, for statutory accounting records.
- Professional advisers, or a public authority, where the law requires disclosure.
Each provider acts on our instructions under a written contract and may not use your data for their own purposes.
7. International transfers
Some of our providers store data outside the United Kingdom. Where that happens, the transfer is covered by UK adequacy regulations or by the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, together with any additional safeguards required. You can ask us which providers are involved and what protection applies.
8. How long we keep data
| Data | Retention period |
|---|---|
| Photographs and video of your hair | 12 months from the end of your programme, then deleted, unless you ask us to delete them sooner |
| Questionnaire answers and written assessments | 24 months from the end of your programme |
| Enquiries that do not become programmes | 6 months from your last message |
| Records of consent to publish images | 3 years after the consent ends, as evidence of what was agreed |
| Curl notes subscription | Until you unsubscribe |
| Payment and accounting records | 6 years, as required by tax law |
9. Security
Images and questionnaire answers are held in access controlled storage, available only to the coaching team working on your programme. Accounts are protected by strong passwords and two factor authentication, devices are encrypted, and material is removed from working folders once a programme ends and the retention period expires. No system is perfect, but we keep the number of people and the number of copies as small as the work allows.
10. Cookies
This website sets no cookies of its own, uses no analytics and no advertising or tracking technologies. Web fonts are loaded from Google Fonts, which means your browser requests those font files from Google and Google receives your IP address as part of that request. No cookie is set by that request. You can block it at browser level and the site will fall back to the fonts already on your device.
11. Your rights
Under UK data protection law you have the right to:
- Access: ask for a copy of the personal data we hold about you, including your images.
- Rectification: have inaccurate data corrected.
- Erasure: ask us to delete your data, including all photographs and video.
- Restriction: ask us to limit how we use your data while a question about it is resolved.
- Portability: receive the data you gave us in a commonly used electronic format, or have it sent to another controller.
- Objection: object to processing based on our legitimate interests.
- Withdraw consent: where we rely on consent, withdraw it at any time.
Write to [email protected] and we will respond within one month. Exercising these rights is free of charge.
12. Withdrawing consent
Where we rely on your consent, you can withdraw it at any time by emailing us or, for curl notes, by using the unsubscribe link. Withdrawal does not affect processing that took place before you withdrew, but it stops that processing going forward. If you withdraw consent for the use of an image that has already been published anywhere, we will remove it from our own channels promptly.
13. Complaints
If you are unhappy with how we handle your data, please tell us first so that we can put it right. You also have the right to complain to the Information Commissioner's Office, the UK supervisory authority, at ico.org.uk or on 0303 123 1113.
14. Age limit
Our programmes are for people aged 18 and over, and we do not knowingly collect data about anyone younger. A parent or guardian may arrange coaching for a child aged 16 or 17 by contacting us directly and taking part in the sessions; in that case they provide the materials and the consent. If we learn that we hold data about a child outside that arrangement, we delete it.
15. Changes to this policy
We update this policy when our practices or the law change. The date at the top of the page shows the current version. If a change materially affects how we handle your images or your rights, we will tell current clients by email before it takes effect.
16. Contact us
VELOURA BEAUTY COSMETICS LIMITED, 16 Frodsham Drive, St. Helens, England, WA11 9BL, United Kingdom.
Email [email protected] or call +44 7481 236094.