Last updated: 19 July 2026

This Privacy Notice for Fabula Garrida Lda (“JWPro”, “we”, “us”, or “our”) describes how and why we may access, collect, store, use, and/or share (“process”) your personal information when you:
• visit our website at jwpro.eu, or any other website of ours that links to this Privacy Notice
• create an account, place an order, or otherwise purchase JWPro products, whether as a retail customer or as a professional cosmetologist partner
• contact us through the website chat, Telegram, or WhatsApp
• engage with us through our marketing channels, including our Telegram group, our Telegram bot, or Instagram

Questions or concerns. Reading this Privacy Notice will help you understand your privacy rights and choices. Fabula Garrida Lda is the data controller responsible for decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you have questions, please contact us using the details in section 11.

Summary of key points

What personal information do we process? When you visit, use, or navigate our Services, we process personal information depending on how you interact with us, including order and account details, professional verification documents if you are a cosmetologist partner, and technical information collected automatically.
Do we process sensitive personal information? We do not seek to collect sensitive personal information. In the limited case where a partner cosmetologist shares a client photograph with us for a product consultation, that image is anonymised or pseudonymised, see section 1.
How do we process your information? To provide and administer our Services, fulfil orders, verify professional status, communicate with you, prevent fraud, and comply with law. We process information for other purposes only with your consent.
With whom do we share information? We share information with our payment processor, our technical service providers, and our order fulfilment staff, as described in section 4.
How long do we keep your information? We keep information for as long as necessary for the purposes described in this notice. If you request erasure, we act on it without undue delay, subject to any legal retention requirement.
What are your rights? Depending on your location, you have rights over your personal information, including access, correction, and erasure, see section 9.

Table of contents
1. What information do we collect
2. How do we process your information
3. What legal bases do we rely on to process your information
4. When and with whom do we share your personal information
5. Do we use cookies and other tracking technologies
6. How long do we keep your information
7. How do we keep your information safe
8. Do we collect information from minors
9. What are your privacy rights
10. Do we make updates to this notice
11. How can you contact us about this notice
12. How can you review, update, or delete the data we collect from you

1. What information do we collect

Personal information you disclose to us

The personal information we collect depends on how you use our Services.

If you order as a retail customer, we collect: full name, email address, phone number, delivery address, and postal code.

If you order or register as a cosmetologist partner, we collect: full name, phone number, email address, business address, company name (where applicable), tax number (where applicable), and a professional certificate or a link to your professional social media profile, which we use to verify your professional status before onboarding you as a partner.

If you ask to be listed in our “find a specialist” directory, we collect the professional and contact information you submit through the listing form. Inclusion in this directory is entirely voluntary and at your request.

If you contact us through our website chat, Telegram, or WhatsApp, we collect the information you choose to include in that conversation.

Sensitive information. We do not seek to collect sensitive personal information. On occasion, a cosmetologist partner may share a photograph of their own client's skin with us to ask whether a product is suitable, including “before and after” images. We anonymise or pseudonymise any such image before further use, and we do not use it for any purpose beyond the consultation unless we separately obtain explicit consent, for example to feature a result on JWPro's social media.

Payment data. If you make a purchase, your payment is processed by Stripe. We do not collect or store your full card number or security code. Stripe's privacy notice is available at https://stripe.com/en-pt/privacy.

All personal information you provide must be true, complete, and accurate, and you must notify us of any changes.

Information automatically collected
This information does not reveal your specific identity but may include IP address, browser and device characteristics, operating system, language preference, referring URLs, and usage data. We collect this information through cookies and similar technologies, described further in section 5.

2. How do we process your information

We process your personal information to:
• create and administer your account
• process and fulfil orders you place, including payment through Stripe and delivery from our warehouse
• verify the professional status of cosmetologists applying to become partners
• maintain the “find a specialist” directory, where you have asked to be listed
• respond to inquiries made through our chat, Telegram, or WhatsApp
• send administrative communications about your order or about changes to this notice
• send marketing communications through channels you join voluntarily, namely our Telegram group, our Telegram bot, and Instagram, and, if you are a cosmetologist partner, through occasional individual messages from your account manager; you may leave these channels or opt out at any time
• protect our Services, including fraud monitoring and prevention
• comply with our legal obligations, including tax and accounting requirements

3. What legal bases do we rely on to process your information

If you are located in the EEA, UK, or Switzerland, we rely on the following legal bases:
• Consent. You can withdraw consent at any time.
• Performance of a contract. To fulfil our obligations to you, including processing and delivering your order.
• Legitimate interests. Where reasonably necessary to achieve our legitimate business interests, provided these do not override your interests and rights, for example to verify a cosmetologist's professional status, to diagnose problems and prevent fraud, and to understand how visitors use our website.
• Legal obligations. Where necessary to comply with tax, accounting, or other legal requirements, or to cooperate with a regulatory authority.
• Vital interests. Where necessary to protect your vital interests or those of a third party.

Fabula Garrida Lda is the data controller of the personal information described in this notice.

4. When and with whom do we share your personal information

We may share your personal information in the following situations:
• Payment processing. With Stripe, to process your payment. A written processor agreement is in place with Stripe.
• Technical service providers. With the developer who maintains our website and order management system, to the extent necessary for them to provide that service. A written processor agreement is in place with our developer.
• Order fulfilment. With staff who prepare and ship orders from our warehouse in Wrocław, Poland, who see the information printed on your invoice (name or company name, tax number where applicable, and delivery address) needed to ship your order and prepare accompanying documentation.
• Business transfers. In connection with any merger, sale of company assets, financing, or acquisition of all or part of our business.

JWPro's distributor for Belarus, ICON DERM LLC, does not have access to the personal information of customers in the EEA or UK, and has no role in the operation of jwpro.eu.
Where a recipient is located outside the EEA or UK, we put in place appropriate safeguards, such as standard contractual clauses.

5. Do we use cookies and other tracking technologies

We use Google Tag Manager for analytics and advertising purposes for analytics.

Most browsers accept cookies by default. You can usually set your browser to remove or reject cookies, though this may affect certain features of our Services

6. How long do we keep your information

We retain personal information, including account, order, and CRM records, for as long as necessary to operate our Services and maintain our business relationship with you, which in practice may mean an extended period. If you request erasure of your personal information, we will act on that request without undue delay, except where we are required by law to retain certain records for longer, such as invoices retained under Portuguese tax and accounting rules

7. How do we keep your information safe

We have implemented appropriate technical and organisational security measures designed to protect your personal information. However, no electronic transmission or storage system can be guaranteed completely secure, and transmission of information to and from our Services is at your own risk.

8. Do we collect information from minors

We do not knowingly collect or solicit information from, or market to, children under 18. By using our Services, you represent that you are at least 18. If we learn that we have collected information from a child under 18, we will take reasonable steps to delete it promptly. If you become aware of any such information, please contact us using the details in section 11.

9. What are your privacy rights

You have the right to:
• request access to and a copy of your personal information
• request rectification or erasure of your personal information
• request that we restrict our processing of your personal information
• receive your personal information in a portable format, where applicable
• object to our processing of your personal information in certain circumstances
• not be subject to a decision based solely on automated processing that produces legal or similarly significant effects concerning you

If you are in the EEA or UK and believe we are processing your personal information unlawfully, you may lodge a complaint with your local data protection authority or, where Fabula Garrida Lda is the relevant controller, with the Comissão Nacional de Proteção de Dados (CNPD) in Portugal. If you are in Switzerland, you may contact the Federal Data Protection and Information Commissioner. Withdrawing your consent.

Where we rely on your consent, you may withdraw it at any time by contacting us using the details in section 11. This will not affect the lawfulness of processing carried out before withdrawal.

10. Do we make updates to this notice

We will update this notice as necessary. The updated version will be indicated by a revised “Last updated” date. Where changes are material, we will notify you by posting a notice on our website or by direct communication.

11. How can you contact us about this notice

You may contact us about this notice by email at info@jwpro.eu, or by post at:
Fabula Garrida Lda
Caminho da Levada dos Tornos, 52
9050-474, Funchal, Portugal
VAT: PT518516253

As Fabula Garrida Lda is established within the European Union, no separate EEA representative has been appointed.

12. How can you review, update, or delete the data we collect from you

You may request access to the personal information we hold about you, ask us to correct inaccuracies, or ask us to delete it, by contacting us using the details in section 11. We will need to verify your identity before responding, and may request additional information for that purpose. We will respond to your request without undue delay.