PRIVACY POLICY

Effective Date: August 13, 2026Last Updated: August 13, 2026

1. Introduction and Scope

This Privacy Policy describes how FOP Topach Oleksandr Oleksandrovych (Tax ID / ЄДРПОУ: 3254006538), operating under the commercial trading name HAIRKILLAH ("HAIRKILLAH", "we", "us", or "our"), collects, uses, stores, discloses, and protects your personal information.
This Privacy Policy applies to personal information processed through our primary website https://hairkillah.com, our learning management system located at https://hairkillahvm.lms.softbook.app, our direct messaging channels, sales funnels, and any associated online education services, downloadable materials, courses, and digital content (collectively, the "Services").
By accessing or using our Services, purchasing our digital educational products, or providing us with your personal information, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

3. Personal Information We Collect

We collect personal information that you provide to us directly, information collected automatically when you visit our Services, and information received from third-party partners.
A. Information You Provide Directly
  • Contact Information: Email address and optional phone number provided when registering for lead magnets, masterclasses, webinars, newsletters, or purchasing courses.
  • Account & LMS Credentials: Username, password, and profile preferences created when accessing our learning platform (Softbook LMS).
  • Payment & Transaction Data: Information necessary to process payments for course access, including transaction history, order details, currency, and purchase timestamps. (Note: We do not store or directly handle your full credit/debit card numbers or banking passwords. All payment details are processed directly by PCI-DSS compliant third-party payment gateways).
  • Customer Support & Communications: Any personal information you provide when contacting us via email, direct messaging platforms, or social media (e.g., Instagram).
B. Information Collected Automatically
When you visit our Website, open our emails, or access our educational content, we automatically collect technical data:
  • Device & Usage Data: IP address, operating system, browser type and version, language settings, device identifiers, time zones, referral sources, pages viewed, time spent on pages, and video engagement metrics (e.g., YouTube playback completion).
  • Location Data: Approximate geographical location derived from your IP address.
  • Tracking Data: Information gathered through cookies, Meta Pixel, Google Ads, TikTok Pixel, and tracking pixels in emails (e.g., email open rates and link clicks).

4. Legal Bases for Processing (UK/EU GDPR)

If you reside in the United Kingdom, European Economic Area (EEA), or Ireland, we process your personal data under the following legal bases:
  1. Performance of a Contract: Processing required to fulfill our obligation to deliver purchased digital products, manage course enrollments, provide customer support, and grant access to the Softbook LMS platform.
  2. Legitimate Interests: Processing required for commercial purposes, such as protecting our intellectual property, preventing fraudulent orders, improving our educational courses, measuring marketing efficacy, and optimizing website user experience—provided your rights do not override these interests.
  3. Compliance with Legal Obligations: Processing required to satisfy legal, tax, accounting, and regulatory obligations.
  4. Consent: Processing based on your specific, affirmative consent (e.g., subscribing to direct email marketing campaigns or accepting non-essential tracking cookies). You have the right to withdraw your consent at any time.

5. How We Use Your Personal Information

We use your personal data for the following legitimate business purposes:
  • Delivering Educational Services: Processing orders, sending order confirmations, granting course access via Softbook, and managing student accounts.
  • Customer Support: Responding to inquiries, troubleshooting platform login issues, and delivering administrative updates.
  • Marketing Communications: Sending newsletter updates, promotional offers, masterclass invitations, and educational content via email or messaging platforms (where permitted by law or based on your consent).
  • Customer Relationship Management (CRM): Managing lead pipelines, tracking customer history, and organizing communications through Pipedrive and SendPulse.
  • Analytics and Personalization: Measuring website traffic, optimizing landing page conversion rates, and refining video production quality.
  • Advertising & Remarketing: Serving relevant online advertising on Meta (Facebook/Instagram), Google, YouTube, and TikTok to potential or returning students.
  • Security & Legal Compliance: Detecting fraud, guarding against unlawful account sharing or unauthorized redistribution of our copyrighted educational materials, and complying with statutory tax obligations.

6. Sharing and Disclosure of Personal Information

We do not sell, rent, or trade your personal information to third parties. We share your personal data only with trusted third-party service providers (processors) necessary to operate our international business:
  • Course Platform & Hosting: Softbook LMS (learning platform hosting) and YouTube Unlisted (embedded video hosting).
  • Payment Processors: Stripe, PayPal, and Lemon Squeezy (Merchant of Record / checkout processing).
  • CRM & Email Automation: SendPulse (email marketing execution) and Pipedrive (customer management).
  • Analytics & Advertising Networks: Google Analytics 4, Meta Platforms (Facebook/Instagram), Google Ads, TikTok, and YouTube Ads.
  • Cookie Management: Cookiebot (Consent Management Platform).
  • Legal and Regulatory Authorities: When required by law, subpoena, or government regulation, or to defend our legal rights, property, and student safety.

7. International Data Transfers

Because we operate an international online education business, your personal data may be transferred to, stored, and processed in countries outside of your country of residence, including Ukraine, European Union member states, and the United States.
Where we transfer personal data originating from the UK, EEA, Canada, or Australia to jurisdictions without an adequacy decision, we rely on legally recognized safeguards, such as:
  • Standard Contractual Clauses (SCCs) approved by the European Commission.
  • The UK International Data Transfer Agreement (IDTA) or UK Addendum.
  • Ensuring third-party processors comply with stringent data security certifications and data protection frameworks.

8. Data Security and Retention

A. Data Security
We maintain administrative, technical, and physical safeguards designed to protect your personal information against unauthorized access, loss, alteration, or disclosure. All transaction checkout pages operate under SSL/TLS encryption. Access to CRM systems (Pipedrive, SendPulse) is restricted to authorized personnel.
B. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected:
  • Account & Purchase Records: Retained for as long as you maintain an active account, plus statutory periods required for financial, accounting, and tax compliance (typically 5 to 7 years).
  • Marketing Data: Retained until you unsubscribe or withdraw your consent.
  • Support Inquiries: Retained for up to 3 years following resolution.

9. Your Legal Rights (Jurisdiction-Specific)

Depending on where you reside, you possess specific statutory rights regarding your personal information:
A. United Kingdom, EEA, and Ireland (UK/EU GDPR)
  • Right of Access: Request a copy of the personal data we hold about you.
  • Right to Rectification: Request correction of inaccurate or incomplete data.
  • Right to Erasure ("Right to be Forgotten"): Request deletion of your data where no overriding legal justification exists.
  • Right to Restrict or Object: Object to processing based on legitimate interests or direct marketing.
  • Right to Data Portability: Request a structured machine-readable transfer of your data.
  • Right to Withdraw Consent: Withdraw marketing consent at any time without affecting prior lawful processing.
B. United States Residents (including California CCPA/CPRA)
  • Right to Know / Access: Request disclosure of categories and specific pieces of personal data collected.
  • Right to Delete: Request deletion of personal information.
  • Right to Correct: Request correction of inaccurate personal details.
  • Right to Opt-Out of Sale / Sharing: We do not sell personal information for monetary value. However, opting out of cross-context behavioral advertising (via our Cookie Banner or GPC signal) limits advertising tracking.
  • Non-Discrimination: We will never discriminate against you for exercising your statutory privacy rights.
C. Canadian Residents (PIPEDA & CASL)
  • Right to Access & Correct: Request access to your personal information and request corrections.
  • Marketing Opt-Out (CASL): You may opt out of receiving commercial electronic messages at any time using the "Unsubscribe" link in our emails.
D. Australian Residents (Privacy Act 1988 / APPs)
  • Access & Correction: Request access to your personal details held by us and request correction if inaccurate or out of date.
  • Complaint Handling: You have the right to lodge a complaint about how we handle your personal data.

10. Children’s Privacy

Our Website, educational courses, and digital materials are directed at adults and professionals. We do not knowingly collect or solicit personal information from children under the age of 18 (or under 13/16 in certain jurisdictions).
If you are a parent or guardian and believe that a minor has provided us with personal information without parental consent, please contact us immediately at info@hairkillah.com, and we will promptly delete such information from our systems.

11. Third-Party Websites and Social Media

Our Services may contain links to third-party platforms, social media networks (e.g., Instagram), or external web resources. We are not responsible for the privacy practices, content, or compliance of third-party websites. We encourage you to review the privacy policies of any external site you visit.

12. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time to reflect legal changes or updates in our operational business practices. Any modifications will be posted on this page with an updated "Last Updated" date. Your continued use of our Services following any modifications constitutes acceptance of the updated policy.

13. How to Exercise Your Privacy Rights or File a Complaint

To exercise any of your privacy rights, or if you have a complaint regarding how your personal information is managed, please contact us at:
If you are a resident of the UK or EEA and are unsatisfied with our response, you have the right to lodge a complaint with your local data protection authority: