Privacy Policy
1. Identity of the Controller and Processor
LATAM TECH EXPANSION ADVISORY LLC, a limited liability company organized under the laws of the State of Florida, United States of America, with EIN 42-1926652, with its principal place of business at 532 Bell Prairie Circle, Lake Wales, FL 33859, USA, operating commercially as LTEA Advisory ("LTEA"), operates the SaaS platform known as LTEA Saloon, available at https://ltea-advisory.com/ltea-saloon.html.
For the purposes of applicable privacy laws, LTEA acts in two distinct capacities:
- As a Data Controller / Business: With respect to the personal data of salons, barbershops, spas, studios, and their professionals and administrators who subscribe to the Platform ("Subscribing Clients").
- As a Data Processor / Service Provider: With respect to the personal data of end consumers of the salons ("Salon Clients") entered into the Platform by Subscribing Clients. In this capacity, the salon is the Data Controller.
2. Personal Data We Collect
2.1. Subscribing Clients (Salons and Professionals)
- Identification and Contact: Full name, corporate email, phone number, job title, and establishment name.
- Business Data: Business registration number (EIN/CNPJ), address, and billing information.
- Payment Data: Credit/debit card information processed securely by Stripe. LTEA does not store complete card numbers.
- Platform Usage Data: Access logs, account settings, system preferences, and interface interaction data.
2.2. End Consumers (Salon's Clients)
- Identification and Contact: Full name, email address, and phone number.
- Preference and Profile Data: Preferred language and locale, hair/skin profile, reported allergies and sensitivities, and service preferences.
- Historical Data: Appointment history, services performed, responsible professional, and purchase/sales history.
- Media Data: Photographs taken before the service and before-and-after images, when captured by the establishment.
- Feedback Data: Ratings and comments about services rendered.
3. Purposes of Processing and Legal Basis
- Platform Operations and Service Delivery: To enable scheduling, calendar management, cash control, commission calculation, and other Platform features. Legal Basis: Performance of a Contract; Legitimate Interest.
- Transactional Communications: Appointment confirmations, reminders, attendance confirmations, and cancellation notifications. Legal Basis: Performance of a Contract; Legitimate Interest.
- Billing and Financial Management: Processing subscription payments and issuing invoices. Legal Basis: Performance of a Contract; Compliance with Legal Obligation.
- No-show Risk Analysis: Analysis of appointment history to identify absence patterns. This profiling serves exclusively as decision support for the salon and does not constitute automated decision-making with legal effects. Legal Basis: Legitimate Interest.
- Service Improvement: Collection of reviews and usage analysis to improve Platform features. Legal Basis: Legitimate Interest or Consent, as applicable.
4. Data Sharing and Subprocessors
LTEA does not sell, rent, or trade personal data. Data sharing occurs exclusively with:
- Supabase (Supabase Inc.): Relational database, user authentication, and cloud file storage. Servers in the United States.
- Resend (Resend Inc.): Transactional email delivery. Data processed in the United States.
- Stripe (Stripe, Inc.): Payment processor for subscriptions. Data processed in the United States, PCI-DSS compliant.
- Google Maps (Google LLC): Used exclusively to generate establishment location links. No personal data transferred.
5. Data Storage and International Transfers
LATAM TECH EXPANSION ADVISORY LLC is a U.S.-based company. All data is primarily stored on servers located in the United States of America. For users outside the US (including Brazil and the European Union), LTEA ensures appropriate safeguards are in place, including standard contractual clauses compliant with applicable law.
6. Data Retention
- Subscribing Client Data: Retained during the subscription term and, after cancellation, for five (5) years to comply with tax and legal obligations.
- End Consumer Data: Retained while the salon's contract is active. After account closure, data will be anonymized or deleted within ninety (90) days, unless otherwise required by law.
7. Data Security
LTEA implements appropriate technical and organizational measures including: data encryption in transit (TLS/HTTPS) and at rest, role-based access control (RBAC), two-factor authentication, and continuous security monitoring.
8. Your Privacy Rights
Depending on your jurisdiction, you may have the following rights:
- Right to Know / Access your personal data
- Right to Correct inaccurate data
- Right to Delete your personal data
- Right to Data Portability
- Right to Opt-Out of Sale (LTEA does not sell personal data)
- Right to Non-Discrimination for exercising privacy rights
- Right to Human Review of Automated Decisions (GDPR Art. 22)
End Consumers: Because LTEA acts as a Service Provider with respect to salon client data, requests to exercise privacy rights should be directed primarily to the Salon (Data Controller). LTEA will provide the salon with the technical tools necessary to fulfill such requests.
9. Cookies and Tracking Technologies
The Platform may use cookies for session authentication, user preferences, and performance analysis. Strictly necessary cookies are used without prior consent. Analytical or marketing cookies, if used, will require your express consent.
10. Children's Privacy
The Platform is not intended for direct use by individuals under the age of 13 (or 16 where applicable under GDPR). If a salon serves minor clients, it is the salon's responsibility (as Data Controller) to obtain parental or guardian consent for data processing, in compliance with applicable law, including COPPA.
11. Changes to This Policy
LTEA reserves the right to update this Policy periodically. Material changes will be communicated to Subscribing Clients by email with at least thirty (30) days' prior notice.
Contact & Data Protection
To exercise your rights, clarify questions, or file complaints about data processing:
- Company: LATAM TECH EXPANSION ADVISORY LLC (LTEA Advisory)
- Email: heloo@ltea-advisory.com
- Address: 532 Bell Prairie Circle, Lake Wales, FL 33859, USA
If you are located in the European Union or the United Kingdom, you also have the right to lodge a complaint with your local data protection supervisory authority.