Privacy Policy

This privacy policy sets out how Ruuby Limited (“Ruuby”, “we”, “us” or “our”) uses and protects your personal data. 

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. It applies to your use of our website at ruuby.com, our mobile applications (including the Ruuby customer app and the Ruuby PA professional app), our messaging channels (including email, SMS and WhatsApp) and any related services (together, the “Services”). Ruuby operates a premium beauty and wellness marketplace connecting customers with vetted professionals across the United Kingdom, United Arab Emirates, Switzerland, and selected European markets (including the South of France). This policy applies to all customers, professionals, and visitors to the Services, wherever they are located. Where local law in your jurisdiction provides you with additional or different rights, those rights apply in addition to those described in this policy.

1. Important Information and Who We Are

1.1 Privacy policy

This privacy policy gives you information about how Ruuby collects and uses your personal data through your use of the Services, including any data you may provide when you register with us, sign up to our newsletter, make a booking, enter a promotion, correspond with us, or otherwise interact with the Services.

1.2 Controller

Ruuby Limited (company number 08910845) is the controller and responsible for your personal data (collectively referred to as “Ruuby”, “we”, “us” or “our” in this privacy policy). Our registered office is at 28 Orchard Rd, Lytham, St Annes, Lancashire, FY8 1PF. Ruuby Limited acts as the controller for all personal data processed in connection with the Services across all markets in which we operate, including the UK, UAE, Switzerland, and the EEA.

If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).

1.3 Applicable data protection laws

Because we operate across multiple jurisdictions, different data protection laws may apply to your personal data, including:

• UK: the UK GDPR and the Data Protection Act 2018, regulated by the Information Commissioner’s Office (ICO).

• EEA: the EU General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”), regulated by the supervisory authority in the relevant member state.

• Switzerland: the revised Federal Act on Data Protection (revFADP), regulated by the Federal Data Protection and Information Commissioner (FDPIC).

• UAE: Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the “UAE PDPL”) and, where applicable, the DIFC Data Protection Law No. 5 of 2020 or the ADGM Data Protection Regulations 2021.

Where required by law, Ruuby has appointed a representative in the EEA under Article 27 EU GDPR. Details of our EU representative are available on request at privacy@ruuby.com.

2. The Types of Personal Data We Collect About You

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

2.1 If you do not provide personal data

Where we need to collect personal data by law, or to perform a contract we have with you (such as delivering a treatment), and you do not provide that data, we may not be able to provide the Services. We will let you know if this is the case at the time.

3. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• create an account on our website or mobile app;

• make a booking, request a quote, or purchase a gift voucher;

• subscribe to our newsletter or publications;

• request marketing to be sent to you, including by opting in to SMS or WhatsApp communications

• enter a competition, promotion or survey;

• give us feedback or contact us

• apply to join Ruuby as a beauty or wellness professional.

Automated technologies or interactions. As you interact with our website and apps, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

• Technical Data from analytics providers such as Google Analytics, advertising networks including Rakuten Advertising, Google, Meta/Facebook and TikTok, and search information providers, all based inside or outside the UK.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services, including Braintree (a PayPal service) for payment processing, based inside or outside the UK.

• Messaging metadata from providers such as Meta Platforms (operator of the WhatsApp Business Platform), our SMS gateway providers and our email service provider (HubSpot), including delivery and read receipts and opt-out signals.

• Identity and Contact Data from data brokers, aggregators or identity-verification providers, based inside or outside the UK.

• Identity and Contact Data from publicly available sources such as Companies House and professional registers based inside the UK.

• Feedback and booking information from beauty and wellness professionals on our platform.

4. How We Use Your Personal Data

4.1 Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to.

• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter or opt in to receive marketing via WhatsApp.

• Vital interests: in the rare case where processing is necessary to protect your or another person’s life.

In the UAE, we rely on the equivalent lawful bases under the UAE PDPL, including your consent and the necessity of processing to perform a contract, comply with a legal obligation, protect vital interests or pursue legitimate interests. In Switzerland, we process personal data in accordance with the revFADP; we do not require a specific legal basis to process non-sensitive data but will not process data in a way that is unlawful, disproportionate or contrary to good faith.

4.2 Purposes for which we will use your personal data

We have set out below, in table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

4.3 Direct marketing

During the registration process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from Ruuby via email, SMS, WhatsApp, telephone and push notification. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view on which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Phone number, SMS and WhatsApp communications

Because messaging is central to how we deliver a concierge experience, we have set out below in detail how we use the telephone number you provide to us.

Channels. We may contact you using the telephone number associated with your account via SMS; via WhatsApp (through the WhatsApp Business Platform, operated by Meta Platforms Ireland Limited or its UAE-based WhatsApp entity where applicable); occasionally by voice call to resolve a live booking issue; and via push notification through our mobile apps, where you have enabled push on your device.

Transactional messaging. We send transactional messages to operate your booking and account (booking confirmations and reminders, professional arrival updates, payment receipts, rescheduling or cancellation notices, security alerts and essential updates). We rely on performance of the contract and our legitimate interests. Transactional messages cannot be switched off without closing your account because they are necessary to deliver the Services.

Marketing and re-engagement. Where you have opted in (or, for SMS and email to existing customers, where the “soft opt-in” applies in your jurisdiction and you have not opted out), we may send you marketing messages, offers, announcements and re-engagement campaigns. WhatsApp marketing always requires your prior opt-in. We will never send unsolicited marketing messages on WhatsApp. When you opt in, we keep a record of your consent — including the date, the method and the wording you saw — so we can demonstrate compliance with applicable law.

Two-way concierge conversations. Our concierge team uses SMS, WhatsApp, in-app chat, email and phone to help you book, manage appointments and answer questions. We process the content of these conversations to respond to you, to resolve issues, to train and improve our team, and to maintain a history of our interactions for quality and customer-care purposes.

Automated and AI-assisted messaging. Some of our messaging is automated (for example, booking confirmations) or AI-assisted (for example, using large language models to draft replies or suggest responses to our concierge team). A human reviews AI-drafted responses before they are sent for any non-routine matter; we do not use AI tools to make decisions that produce legal or similarly significant effects on you without human review; and we select providers that offer appropriate data-protection safeguards and do not train their models on your personal data without our express instruction.

4.4 Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes. We do not sell or trade your personal data with third parties for their own marketing purposes.

4.5 Opting out of marketing

You can ask us to stop sending you marketing communications at any time by logging into the website or app and updating your marketing preferences, by following the opt-out links within any marketing communication sent to you, or by contacting us.

Channel-specific opt-outs:

• SMS marketing: reply STOP (or the equivalent keyword shown in the message) to unsubscribe.

• WhatsApp marketing: reply STOP, use the “Stop promotions” button where shown, or block our WhatsApp business account.

• Email marketing: use the “unsubscribe” link in any marketing email.

• Push notifications: disable push notifications for the Ruuby app in your device settings.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes (for example, booking confirmations, appointment reminders, or updates to our Terms and Conditions).

4.6 Cookies

We use cookies and similar technologies on our website and apps to make the Services work, to remember your preferences (such as search filters and login state), to understand how the Services are used — including through Google Analytics, which collects standard logging information such as which pages are visited and in which order — and, where you have consented, to personalise content and advertising. Some cookies are set by third parties, including Rakuten Advertising. For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy. To manage third party cookies on our site please click here.

5. Disclosures of Your Personal Data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.

• Beauty and wellness professionals on the Ruuby platform — we share the information they need to deliver your booking, including your name, service address, contact number, booking details and any health or preference information you have chosen to share. Professionals are contractually required to keep this data confidential and to process your data only for the purpose of delivering your treatment.

• Payment providers — Braintree (a PayPal service) — we use Braintree to process card payments. Card details are collected and held directly by Braintree in line with Payment Card Industry (PCI) standards. Braintree acts as an independent data controller for the personal data it processes to provide fraud prevention and payment services; please refer to the PayPal / Braintree Privacy Statement for details of how they process your data. We also support Apple Pay and Google Pay as payment options.

• Email and newsletter provider — HubSpot — we use HubSpot to send our newsletters and certain lifecycle marketing emails, and to collect standard engagement statistics (such as opens and clicks) to help us improve the quality and relevance of our communications.

• Messaging and communications providers — including Meta Platforms (operator of the WhatsApp Business Platform), our SMS gateway provider, and our in-app chat and concierge support platforms.

• Analytics providers — Google Analytics — we use Google Analytics to collect standard logging information such as which pages are visited and in which order, so we can analyse customer and visitor behaviour in aggregate. We do not instruct Google to collect personal data that identifies you individually for our analytics purposes.

• Advertising partners — Rakuten Advertising, Google, Meta/Facebook, TikTok and similar networks — used to deliver and measure advertising, subject to your cookie preferences and (where required) your consent.

• Technology and hosting providers — including our cloud infrastructure providers, database hosts, mobile-app platforms (Apple and Google) and security and identity-verification providers.

• AI and automation providers — including providers of large language model services used to support our concierge team, under terms that prohibit use of your data to train their models without our instruction.

• Professional advisers — including our lawyers, auditors, accountants, insurers and consultants.

• Regulators, law-enforcement authorities and courts — where we are required to disclose data to comply with a legal obligation, enforce our terms, protect our rights or investigate fraud or abuse.

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Where a partner acts as an independent controller (such as Braintree for payment processing), they will apply their own privacy policy to the data they process, and we will make that clear to you.

6. International Transfers

Because we operate across the UK, EEA, Switzerland and the UAE, and because many of our service providers are located outside these regions (including in the United States), your personal data may be transferred to, stored in, or accessed from countries other than the one in which you live.

6.1 Transfers from the UK

Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as UK law, we always ensure that a similar degree of protection is afforded to it by implementing one or more of the following safeguards:

• We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.

• We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement (IDTA) or the International Data Transfer Addendum to the European Commission’s standard contractual clauses.

• For transfers to the United States, where applicable, we rely on the UK Extension to the EU-U.S. Data Privacy Framework with providers who self-certify to it.

6.2 Transfers from the EEA

Whenever we transfer personal data out of the EEA to a country not covered by a European Commission adequacy decision, we rely on one or more of the following safeguards: (a) the European Commission’s Standard Contractual Clauses (2021), with appropriate supplementary measures where necessary following a transfer impact assessment; (b) where applicable, the EU-U.S. Data Privacy Framework with providers who self-certify to it; or (c) adequacy decisions — for example, transfers to the UK and Switzerland are covered by European Commission adequacy decisions.

6.3 Transfers from Switzerland

Transfers of personal data from Switzerland to countries that the Swiss Federal Council has not recognised as providing adequate protection are made under the Swiss addendum to the Standard Contractual Clauses, or, where applicable, the Swiss-U.S. Data Privacy Framework.

6.4 Transfers from the UAE

Personal data collected from customers in the UAE may be transferred outside the UAE in accordance with the UAE PDPL (or, where applicable, the DIFC or ADGM data protection regimes). We only make such transfers where the destination jurisdiction provides an adequate level of protection, or where appropriate contractual safeguards are in place, or with your explicit consent, or where another lawful ground for transfer applies.

To obtain a copy of the contractual safeguards we use, please contact us at privacy@ruuby.com. We may need to redact commercial terms before providing a copy.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Your account and booking information is stored in a private database hosted on a private network with no direct public access, using security and encryption technologies that are compliant with Payment Card Industry (PCI) standards. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so (including, where applicable, within 72 hours under the UK and EU GDPR).

8. Data Retention

8.1 How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

Our standard retention periods include:

• Account and booking records: for the duration of your account and for six years after account closure.

• Financial and transactional records: six years (or longer where required by local tax law, for example in the UAE).

• Marketing preferences and consent records: for as long as you are a customer and for a reasonable period thereafter to evidence compliance.

• SMS and WhatsApp message content: typically up to 24 months from the date of the message, subject to longer retention for disputes, investigations or legal obligations.

• Call recordings (where made): typically up to 6 months, unless a longer period is needed for training, quality or dispute-resolution purposes.

• Technical logs and security data: typically up to 24 months.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

You have a number of rights under data protection laws in relation to your personal data. Ruuby will honour the following rights for all customers, regardless of location, except where local law restricts them.

You have the right to:

• Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data, for example if you want us to establish the data’s accuracy.

• Not be subject to solely automated decisions that have legal or similarly significant effects on you.

Additional jurisdiction-specific rights

Depending on your jurisdiction, you may have additional rights:

• In the UAE (PDPL): the right to request that we stop or limit processing of your data, and (subject to certain conditions) the right to receive information about breaches affecting your data.

• In Switzerland (revFADP): the right to be informed about any automated individual decision-making and, where applicable, the logic involved.

• In the EEA: rights to object to processing for scientific or historical research purposes, where applicable.

If you wish to exercise any of the rights set out above, please contact us (see Contact details, paragraph 10).

9.1 No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

9.2 What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9.3 Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact Details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

• Email: support@ruuby.com

• Postal address: Data Privacy, Ruuby Limited, 28 Orchard Rd, Lytham, St Annes, Lancashire, FY8 1PF

• Telephone: +44 020 460 8319

11. Complaints

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). You also have the right to lodge a complaint with your local data protection authority in the country where you live, where you work, or where the alleged infringement took place. However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand.

12. Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We keep our privacy policy under regular review. This version was last updated on 8th June 2026. We will notify you of any material changes by email, in-app notification, or a prominent notice on our website before the changes take effect.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address — including if you change your phone number, since this will affect SMS and WhatsApp communications.

13. Third-Party Links

This website and our apps may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.