Privacy and cookies
1. Who processes your data
The controller is ROBEXA EOOD, UIC 208809810, 124 Knyaz Boris I Boulevard, apartment 1, Varna, Bulgaria.
Contact for personal data enquiries: info@robexa.app
This policy applies to the ROBEXA BEAUTY mobile application and web version.
2. Who is responsible for what
ROBEXA is a platform. Procedures are performed by salons, studios, medical establishments and academies, referred to below as Partners.
ROBEXA processes your data as a controller for your account, wallet, payments on the platform, vouchers, communications and platform security.
The Partner processes your data as an independent controller for booking and performing the procedure, keeping its own records and fulfilling its legal obligations. The relevant Partner’s privacy policy applies to these purposes.
ROBEXA is not responsible for the Partner’s processing of data outside the platform.
3. What data we process
Upon registration: phone number or email address, name, encrypted password and registration date.
Upon full verification: identity verification result, date and reference number from the service provider. We do not store images of your identity document or selfie capture.
When topping up and paying: amount, date, transaction status, last four card digits and card type, and identifier from the payment service provider. We do not store full bank card numbers or CVV codes.
Upon purchase: purchased offers, value, Partner, voucher number and status, validation date and balance history.
When communicating: chat messages with Partners, reports, complaints and correspondence with support.
Technical data: IP address, device type and model, operating system, application version, device identifier, access logs and error logs.
When applying for a collaboration: links to social profiles, portfolio and application text that you provide voluntarily.
4. Nature of the services offered
Offers on the platform are aesthetic and cosmetic in nature. Publishing offers presented as treating or affecting a disease or medical condition is not permitted.
The platform chat is not intended for exchanging medical information. Please do not use it to send diagnoses, medical documents or medical images. Contact the Partner directly for such communications.
Where a procedure is performed by a medical establishment, informed consent is given to that establishment. ROBEXA does not collect or store it and does not process medical records.
5. Why we use the data and on what legal basis
| Purpose | Legal basis |
|---|---|
| Creating and maintaining an account; performance of the Terms and Conditions | performance of a contract — Article 6(1)(b) |
| Processing payments, maintaining the wallet and issuing vouchers | performance of a contract — Article 6(1)(b) |
| Identity verification for higher limits | performance of a contract and legitimate interests — Article 6(1)(b) and (f) |
| Preventing fraud and misuse | legitimate interests — Article 6(1)(f) |
| Handling reports, complaints and disputes | legitimate interests and legal obligation |
| Accounting and tax reporting | legal obligation — Article 6(1)(c) |
| Offer notifications and marketing | consent — Article 6(1)(a) |
| Analysing usage and improving the platform | legitimate interests — Article 6(1)(f) |
We send marketing messages only with your consent. You can withdraw it at any time in the settings or through the unsubscribe link.
6. Who we share data with
The Partner from whom you have purchased a voucher or to whom you have applied: your name, contact details, purchased offer and voucher number, to the extent necessary to perform the procedure.
Service providers acting on our instructions: a notification delivery provider and, where applicable, technical providers serving the platform.
Payments and identity verification are carried out directly by licensed providers in a separate process. Their own privacy policies apply to these operations.
Competent authorities where we are legally required to do so.
We do not sell your data to third parties.
7. How long we retain data
| Category | Retention period |
|---|---|
| Account and verification data | until account closure, then 12 months |
| Payment and voucher data | 5 years under accounting and tax legislation |
| Chat messages | 12 months |
| Reports, complaints and disputes | 3 years after closure |
| Marketing data | until consent is withdrawn |
An account frozen due to inactivity is retained with its available balance until reactivation or closure at your request.
8. Automated decisions
We apply automated transaction checks to prevent fraud. These may result in temporary restrictions on topping up or using your balance.
Such a restriction is not a final decision. You have the right to challenge it, and every challenge is reviewed by a staff member. Contact info@robexa.app.
9. Your rights
You have the right to request access to your data, rectification, erasure, restriction of processing and portability, and to object to processing based on legitimate interests. Where processing is based on consent, you may withdraw it at any time.
Requests should be sent to info@robexa.app. We respond within one month.
We cannot delete certain data while we are legally obliged to retain it, for example payment data.
You have the right to lodge a complaint with the Commission for Personal Data Protection, 2 Prof. Tsvetan Lazarov Boulevard, Sofia 1592, Bulgaria, kzld.bg.
10. Security
We apply technical and organisational measures to protect data, including connection encryption, access controls and audit logging. Payments are processed by licensed providers using strong customer authentication (3-D Secure).
11. Age
The platform is intended for persons aged 18 or over. We do not knowingly collect data from anyone under that age. If we identify such a case, we delete the data.
12. Cookies in the web version
We use:
- essential cookies for sign-in, sessions and security; the platform cannot function without them, and they do not require consent;
- analytics cookies for usage statistics;
- marketing cookies for measuring advertising.
Analytics and marketing cookies are used only after you give consent through the banner on your first visit. You can change your choice at any time using the Cookie settings link.
13. Changes
We will notify you in the application or by email of material changes to this policy.