1.1          This Privacy Policy (hereinafter referred to as the “Policy”) describes the procedure implemented by KG Connect Limited, company registered at the address: 15/F., BOC Group Life Assurance Tower, 136 Des Voeux Road Central, Central, Hong Kong, and its affiliates and authorized representatives (hereinafter referred to as the “Company”) to collect and use the personal data, when using the service for providing of private beauty services at https://getmanicure.com (hereinafter referred to as the “Service”), including the contents, purpose of use and disclosure of the collected information to the third parties, as well as the rights of the Users with respect to such information. This Policy covers all persons, providing information in connection with the use of the Service (hereinafter referred to as the “Users”) while they use the Service through the site, mobile applications, any additional functions and services throughout the world. 

    1.2          The Company reserves the right to make at its own discretion any amendments to this Policy at any time and without any special notice to this effect. The new version of this Policy shall come into effect upon posting of the same on the Site. Continuing using the Service, the User confirms its consent to comply with the terms and conditions of the Policy in its current version. The Company recommends the Users to review the Policy more often in order to make sure that the User understands the terms, while using the Service. If the User does not agree with the terms of the Policy amended by the Company, he/she shall not be entitled to use the Service and may send a written request to the Company’s email address info@getmanicure.com (hereinafter referred to as the Company’s email) to stop receiving and use, as well as to delete all data regarding the User, including addresses, names, contacts, cookies, etc.

    1.3          This version of the Policy shall come into effect on from June 1 2019 and remain valid until approval of a new version.


    2.1. The Company may receive the following information on the Users during the Service use:

    2.1.1. When the beauty services are ordered through the Service or the Service is used, the information on the Users may include:

    • name (nickname),
    • photographs,
    • e-mail address,
    • telephone number,
    • details of registration in social media,
    • information on devices used for access to the Service and cookie files,
    • other Personal data of the User.

    The Service shall not in any way get access to and process the payment information of the Users (bank cards details, bank account details etc.) during the order of transfers or use of the Service as passenger by the Users. The payment recitals of the Users, specified when filling out the form for the service order, is transferred to the payment system directly.

    2.1.2. Information on the Users may be provided by:

    – filling out respective forms in the Service by the Users,

    – submitting respective data to e-mail of the Company by the Users,

    – collection of information during the use of the Service, including by placement of orders for the beauty services and completion of the same.

    2.2. The Company may collect and process information through provision of information on the Customers to its affiliates, subsidiaries or contractors, which executed service agreements with the Company, including the necessity of processing of above data. Irrespective of where the data are processed, the Company shall implement the same actions for security of the same, which actions are described herein.

    2.3. Depending on the requirements of the legislation of the country in which the Company renders services and the location of the User, the User, by working with the Service, voluntarily sending and providing his personal data to the Company, paying for services, as well as performing other conclusive actions confirming the User’s consent to work with the Service at the same time confirms its agreement with all, without exception, requirements of this Policy, as well as, if such is provided for by the legislation of the User’s country, confirms his consent to the collection, recording, systematization, accumulation, storage, refinement (update, change), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and / or destruction of such personal data, by the Company in full and without additional notice to the User.


    3.1. The Company shall be entitled to use information provided by the Users for communication with the Users, in order to check the data, ensure completion and payment of the services, and for mailing information and marketing messages.

    3.2. The Company shall be entitled to transfer information to its suppliers, consultants, marketing partners, research entities and any other service providers or business partners. During the transfer of information in compliance with this paragraph, the Company shall take steps to process information in compliance with the guidelines and Privacy Policy of the Company, as well as any other applicable regulations on confidentiality and security.

    3.3. The Company may transfer data on the Users, if that it is required by applicable law, regulation, valid contract, court proceedings or request issued by a public authority, or if such information needs to be disclosed for the settlement of conflict situations (in particular, with respect to completion and/or payment of the beauty services), ensuring security to the Users or the Service, in case of any claims and disputes, related to getting services under the Service and others by the Users.

    3.4. The information on the Users may be provided by the Company to the third parties in connection with such events as merger or sale of the Company’s assets, amalgamation and restructuring, financing and acquisition of a business as a whole or in part, or during the negotiations of such matters.

    3.5. The Company may disclose information to the third parties in situations, which are not expressly stated hereby, subject to obtaining the User’s consent to disclosure of information pertaining to him/her.



    4.1. The Company keeps the information and any other data about the User until the Service gets the User’s request for deletion of such information or data to the Company’s email.

    In order to comply with any legal, fiscal, insurance and any other requests, which are effective in compliance with applicable law, User support, improvement of the service quality, research and analytics with respect to the Service use, direct marketing and for any other operational purposes, the Company keeps all the information about the Users that may be received in accordance with this Privacy Policy, including information on payments of beauty services, as well as of the devices used for the use of the Service, and during 7 (seven) years after the information about the User is deleted. Upon expiry of this term the Company shall delete or anonymize such information in compliance with applicable legislation.

    4.2. The Users may at any time send the request for deletion of personal data of the User. Upon receipt of such request, the Company shall delete all information on the User, except for the information that must be kept and shall restrict access of any third parties, including the Service Users, to data on such User which remains in the Service. The Users hereby accept and agree, that even in case of deletion of personal data of the User, the information on the User may be provided by request of the third parties, in particular, if any conflict situation, related to completion or payment of the beauty services needs to be settled, for the purposes of ensuring security of the Users or the Service, prevention or investigation of any cases of fraud, etc.


    5.1. The requests and demands for receipt of any User information, change of information if such information is not correct, deletion of Personal Account and refusal to receive marketing information from the Company may be sent to the Company’s email info@getmanicure.com.

    1. COOKIES

    6.1. The website of the Company uses “cookies”. Information that Company gets through the cookies helps to deliver services in the most convenient way.

    By using this website, the User agrees with the placement of cookies in his device under the terms of this Agreement.

    If the User doesn’t agree with the using cookies by the Company, the User need either to customize respectively the settings of his browser for Control or Disabling of the cookies in his device or not to use this website and exit it.

    6.2. Information on cookies

    Cookies are the small text files downloaded by internet browser of the User to his PC/tablet computer, telephone or any other device used by the User for access to the website.

    Cookies are used in order to ensure a personalized experience of the site use and convenient site navigation. They help to track the most visited web pages, determine the efficiency of advertising and web searches, and give an indication of the User behavior, thereby contributing to improvement of communication means and products offered to Users. The cookies also help the User not to lose data inserted into the request form, when the site page is refreshed.

    Cookies that the Company saves through the website do not contain any data enabling to identify the User.

    Please note that the Company do not guarantee a correct work of the Company’s website in the User’s browser, should the User disable the option of cookies storage.

    6.3. Used cookies

    The Company uses the cookies of the following types:

    1. Performance cookies.

    These cookies collect information on using of the websites such as, for example, information on the most visited by User pages of the site. They can be used by the Company for optimization of the websites and navigation facilitation. These cookies are also used by the Company’s affiliates to establish a fact of visit to the site from the site of affiliates; a fact of use of the website’s services. The performance cookies are not used for collection of personal data of the website User. All information collected with such cookies is intended for the purposes of statistics and remains anonymous.

    1. Functionality cookies.

    These cookies help the websites to remember the choice made by the User, when browsing the website. Such cookies can also be used to remember the settings like a font type and font size of the text, and any other adjustable parameters of the website. The functionality cookies can be used to track the recommended services and videos of the Company in order to prevent the repetition of the same. The functionality cookies help the User not to lose the data inserted into the request form in the website. The information provided by the functionality cookies does not enable User identification and tracking of the User’s experience in the websites, which are not related to the Company.

    1. Advertising cookies.

    These cookies record data on User actions in the web, including visits to the sites and pages, and data on the links and advertisements clicked by the Users for browsing. This is necessary to display on the websites the content, which is the most targeted for the User, and to ensure the opportunity to provide the advertising or any other information, which is the most compliant with the User’s interests. The Company, together with the third parties, including the technological partners and service providers, participates in advertising targeted to the interests of Users, delivering the advertisement and the personalized content, which, in Company’s opinion, will be of interest for the User.

    6.4. Cookies management

    Most web browsers are preset to accept cookies. The User may change settings to block the cookies by the browser or to get notifications, when such files are sent to the device. There are several ways to manage cookies. Read the browser manual please to learn more about how to adjust or change the browser settings.

    Please keep in mind that some personal services can’t be delivered to the User and the User selecting such settings can’t get a full access to all sections of the website.

    6.5. Term of storage of cookies

    Some cookies operate from the moment of the User’s access to the site till the end of a particular session in the browser. These files become useless and they are automatically deleted upon closing the browser. Such files are called session cookies.

    Some cookies are also saved on device between the sessions in browser and they are not deleted after the browser closing. Such cookies are called persistent cookies.

    6.6. Additional terms and conditions

    THE TERMS OF THIS POLICY APPLY TO ALL WEBSITES OF THE COMPANY WITHOUT REGARD TO HOW THE USER GETS ACCESS TO THE NETWORK. BY ACCESSING THE WEBSITE THE USER AGREES WITH THE TERMS OF POLICY EACH TIME THE USER VISITS THE SITE WITH ANY DEVICE. ANY AMENDMENTS MADE TO THE POLICY WILL BE PUBLISHED HERE. This Policy may be amended and/or supplemented by the Company on its own discretion without any special notification. This Policy is an open and public document. The valid version of Policy is available in the web at getmanicure.com. The Company recommends the Users to check regularly the terms and conditions of this Policy for any amendments and/or supplements.