Privacy

Terms & Conditions – Professionals Last updated: February 15, 2026 These Terms & Conditions (“Terms”) govern the use of the SYSTEM application (“Application”), operated by System Modular Hair Product Inc. (“SYSTEM”), by professional hairdressing salons and practitioners (“Professionals”). By accessing or using the Application, you agree to these Terms. About the Service SYSTEM provides a professional tool for personalized hair care products. The Application supports hair professionals by generating personalized formulation recommendations based on information and images provided during the service session (the “Service” or “Session”). Professional use only The Application is currently intended solely for use by trained hairdressing professionals in a professional setting. Professionals agree to use the Application in accordance with SYSTEM’s applicable guidelines and instructions, as made available to Professionals through the Application and as may be updated from time to time. Decision support tool The Application is a decision-support tool. While automated processing generates formulation recommendations, the professional remains responsible for reviewing, adjusting, and approving the final product based on their professional judgment and the client's specific needs. Responsibility toward clients Professionals are solely responsible for their relationships with end clients, including consultations, explanations, suitability assessments, sensitivity checks, and the final application or recommendation of products. The Application provides guidance only and does not replace professional responsibility. Accounts and access Professionals are required to create an account to access the Application. You are responsible for maintaining the confidentiality of your login credentials and for all activity under your account. Data processing To the extent that Professionals process personal data on behalf of SYSTEM when using the Application, such processing is governed by the Data Processing Agreement incorporated into these Terms. Fees and payments At this stage, no payments are processed through the Application. Any commercial arrangements, commissions, or future fees will be governed by separate agreements if applicable and/or by adjustments to these Terms. Intellectual property All rights in the Application, including software, algorithms, recommendations, designs, and content, are owned solely by SYSTEM or its licensors. Professionals receive a limited, non-exclusive, non-transferable right to use the Application solely for its intended professional purpose. Acceptable use Professionals agree not to: • Use the Application for any unlawful, misleading, or non-professional purpose • Represent recommendations as medical or therapeutic treatments • Copy, reverse engineer, or attempt to derive the underlying technology • Use the Application to develop competing products or services • Allow unauthorized third parties to access the Application Privacy Information about how personal data is handled in connection with the Application and the Services is described in SYSTEM’s Privacy Policy, available at . Suspension or termination SYSTEM may suspend or terminate access to the Application if these Terms are violated or if use of the Application poses legal, regulatory, or security risks. Disclaimer The Application is provided in good faith to support professional hair care services. While we strive for accuracy and reliability, results may vary depending on inputs and professional judgment. Future Client access/modifications SYSTEM may, in the future, offer features allowing end clients to access profiles, manage information, or place orders directly. Such use may be subject to additional terms communicated at that time. SYSTEM may also amend the contents and information included in the Application as well as these Terms, from time to time. Governing law These Terms are governed by the laws of England and Wales, and the courts of England and Wales shall have jurisdiction over any dispute arising under these Terms. Contact If you have questions about these Terms, please contact us at info@systemhair.com. Data Processing Agreement (DPA) This Data Processing Agreement (“DPA”) forms part of the Terms & Conditions governing the use of the SYSTEM application (“Application”). Last updated: 15, 2026 Roles of the parties SYSTEM acts as the Data Controller. The professional hair salon or practitioner (“Professional”) acts as a Data Processor, processing personal data solely on behalf of SYSTEM and in accordance with SYSTEM’s documented instructions. For the purposes of this DPA, SYSTEM’s documented instructions include its operational and privacy-related instructions and guidelines made available to Professionals through the Application and as may be provided to them by SYSTEM in writing, and may be updated from time to time. Scope of processing The Professional processes personal data only for the purpose of providing personalized hair care services through the SYSTEM Application, including the collection and submission of photos and related information, strictly as instructed by SYSTEM. Processor obligations The Professional agrees to: • Process personal data only on documented instructions from SYSTEM • Treat all personal data processed under this DPA as confidential and, where applicable, ensure that any other person authorized to process such data is subject to a similar duty of confidentiality. • Implement appropriate technical and organizational measures to protect personal data • Not use personal data for any independent purpose or retain copies • Promptly notify SYSTEM of any personal data breach or security incident Sub-processing The Professional may not engage sub-processors without SYSTEM’s authorization. Where authorized, the Professional shall ensure that equivalent data protection obligations apply. Data subjects’ requests The Professional shall reasonably assist SYSTEM in responding to data subjects’ requests and in complying with applicable data protection obligations, including cooperation with supervisory authorities where required. Deletion or return of data The Professional shall not retain any personal data processed on behalf of SYSTEM outside the Application. Upon termination of the Professional’s use of the SYSTEM Application, the Professional shall ensure that no such data, including any copies, exports, or locally stored information, remains in its possession. For the avoidance of doubt, personal data stored within SYSTEM’s Application and infrastructure remains under SYSTEM’s control and is managed by SYSTEM in accordance with its data retention policies. Audits and compliance Upon reasonable request, the Professional shall provide information necessary to demonstrate compliance with this DPA. On-site audits will be conducted only where reasonably necessary. Liability Each party remains responsible for its own compliance with applicable data protection laws. Professionals may process personal data only in accordance with SYSTEM’s documented instructions and applicable law, and shall be solely responsible for any processing of personal data outside SYSTEM’s instructions. Governing law This DPA is governed by the laws of England and Wales , and the courts of England and Wales shall have jurisdiction over any dispute arising under these Terms. Precedence In the event of any conflict between this DPA and the SYSTEM’s Terms & Conditions, this DPA shall prevail with respect to data protection matters.