Solutions · Beauty & wellness

AI consulting & training for beauty & wellness.

Choosing a starting point and preparing the team. This page places the service mechanics next to the rules that apply in beauty & wellness — without claiming a project we have not done.

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Starting point

What beauty & wellness looks like before any software

The schedule is the business. A salon does not sell a product it can keep on a shelf — it sells an hour from a given person’s day, and that hour, if it passes empty, is never recovered. From there comes everything else: who replies quickly to the message, who confirms, who reschedules, who calls when someone has cancelled. The person who replies is, as a rule, the one with their hands busy in someone’s hair, and the channel through which the request comes is not the telephone, but a social network’s messaging service, where the conversation never ends and is never archived anywhere.

What the salon calls the ‘client file’ is, in fact, two overlapping things. One is commercial and harmless: what service was done, for whom, with what product, what shade, how much was paid. The other slips in through the free field at the end, where the master notes what was observed or what was said to them — that the skin reddened after the last procedure, that she is pregnant, that she is taking treatment, that she had a reaction to something. The second is not a more detailed version of the first. It is another category of data, with another regime, in the same table row.

The before/after photo is, at the same time, the industry’s main sales tool and the most delicate object it produces. It is taken in the salon, often on a partially undressed person, almost always on the master’s personal phone, and ends up in a gallery that synchronises somewhere. When it shows a hairstyle, it is a photo. When it shows skin with acne before and without after, it shows a state of the body — and that moves it, by content, not by format, into another category from the rest of the gallery.

No-show is not a politeness problem, it is an inventory problem. The salon responds with what it has at hand: it asks for a deposit, keeps track of who did not show up, sends reminders. Each of the three creates processing on a different basis — one relates to the contract, one to an interest of the salon that it must be able to explain, and the third is very easily confused with marketing, which has different rules and an opt-out button that the client can press at any time.

The line between a salon and a medical practice runs through the same door. The same reception, the same schedule, the same phone — but the moment the procedure becomes a medical act carried out by a doctor or another healthcare worker, a set of sector-specific rules that were not there in the morning applies over everything that came before. The salon does not feel the transition, because nothing has changed from the inside: still a client, still an appointment, still a photo.

A statement and its sources

Regulile

What applies in beauty & wellness, with the article it comes from

Each rule below carries the normative act that imposes it. Verification does not require you to take our word for it.

Allergy and skin condition are not client preferences

The law defines health data as data related to a person’s physical or mental health, including data resulting from the provision of services and revealing their condition. A client who says they like warm water and do not want short bangs expresses a preference. A client who says they have dermatitis, that they are allergic to a local anaesthetic or that they are in their twelfth week of pregnancy describes a state of the body. The first is noted freely. The second falls under the general prohibition on processing special categories of data and becomes lawful only through a specific exception, chosen in advance, not justified afterwards.

SourceLaw 195/2024, art. 4 (the definition of “health data”), art. 9 para. (1)

The salon does not have the medical exception. It is left with explicit consent

The exception that allows the processing of health data for diagnosis, treatment or the provision of medical care is conditional on the data being processed by or under the responsibility of a professional bound by professional secrecy. A hairdressing or care salon does not meet the condition, because it does not provide medical care within the meaning of the law — a medical act is defined as being performed by a doctor or another medical worker. The practical consequence is concrete: for the question about contraindications, the only realistic basis remains the client’s explicit consent, given for a specific purpose, and that changes how the form looks, not only what it says.

SourceLaw 195/2024, art. 9 para. (2) lit. h) and para. (3), art. 9 para. (2) lit. a); Law 263/2005, art. 1 (definitions of “medical intervention (medical act)” and “healthcare providers”)

A photograph is not biometrics just because it is a face

It is often repeated that customer photos would be biometric data. The law does not say that. Biometric data are defined as data resulting from specific processing techniques and allowing or confirming unique identification of a person, and the prohibition in the article on special categories refers to biometric data processed for unique identification. A photograph becomes biometric data through the technique applied to it — facial recognition, automatic matching — not because it contains a face. A salon that keeps an ordinary album does not do biometrics, and claiming otherwise shifts the discussion from the real risk to an invented one.

SourceLaw 195/2024, art. 4 (the definitions of “biometric data” and “health data”), art. 9 para. (1)

The same photograph may, however, be health data, by what it shows

The real risk of the before/after photograph is different, and it lies in the content. An image showing a skin condition, a scar, a dermatologically treated area or the effect of a procedure on a state of health reveals the person’s physical health. From that moment it falls under the same regime as a written answer about allergies, even though no one has filled in any form. A hair album and an acne treatment album look the same on a phone and are subject to different rules; the salon that keeps them in the same place implicitly treats both under the rule of the least restrictive one.

SourceLaw 195/2024, art. 4 (the definition of “health data”), art. 9 para. (1)

When the procedure is a medical act, the photograph requires written consent under a second law

The Law on Patients’ Rights expressly states that a patient may not be photographed, filmed or exposed in any other form for demonstration as an object of study in a medical and healthcare institution without the written consent of the patient or of their legal representative. It is not the same requirement as consent under data protection law and they do not cover each other: the first is sector-specific and requires written form, the second requires the request for consent to be presented separately, intelligibly, in clear language. A centre that has added injectable procedures next to care services crosses the line without changing its forms.

SourceLaw 263/2005, art. 13 para. (10), art. 1 (definition of “medical intervention (medical act)”); Law 195/2024, art. 7 para. (2), art. 9 para. (2) lit. a)

Consent cannot be the price of the service, and it is withdrawn just as simply as it is given

When assessing whether consent is given freely, account is taken, in particular, of whether performance of the contract — including the provision of the service — is conditional on consent to processing that is not necessary for that contract. Publishing the photograph on social media is not necessary to cut or treat someone. So “sign here, otherwise we cannot book you” does not produce valid consent, but contestable consent. And withdrawal must be as simple as giving it: if consent was given by ticking a box at reception, withdrawal cannot require a written request at the office.

SourceLegea 195/2024, art. 7 alin. (1)–(4), art. 13 alin. (2) lit. c), art. 17 alin. (1) lit. b)

The appointment reminder is not direct marketing. The offer is

The law defines direct marketing as the communication, by telephone, post or any other direct means of communication, of advertising messages or messages promoting goods or services, addressed to particular persons. A message confirming tomorrow’s time is part of contract performance. A message saying that on Tuesday there is a twenty per cent discount on manicure is direct marketing, and there the person has the right to object at any time, without having to justify the request, and the processing for that purpose stops. The right must be brought expressly to the client’s attention no later than the first communication, separately from any other information — not at the end of a policy.

SourceLaw 195/2024, art. 4 (the definition of “direct marketing”), art. 6 para. (1) lit. b), art. 21 para. (2)–(4)

The threshold of 250 employees does not exempt a small salon from keeping records of processing

The obligation to keep records of processing activities has an exception for undertakings with fewer than 250 employees, but the exception falls away if the processing is likely to generate a risk to the rights and freedoms of individuals, if the processing is not occasional, or if it includes special categories of data. A salon with five people asking about allergies or skin conditions falls under the last; a booking diary kept daily falls under the second. One is enough. The record is not a compliance document for inspections: it is the place where the salon is obliged to write, by category, how long each thing is kept.

SourceLaw 195/2024, art. 30 para. (1) and (5), art. 9 para. (1)

Mecanica

What AI consulting & training does, in concrete terms

The same capabilities that appear on the service page, where each has its own file and back-end line.

We request the primary document for each statement

A register with one statement per line: the primary document, the date, where it is found, whether it is publishable. The document that repeats the statement does not count as a source. Applied to us, the register eliminated three non-existent awards and confirmed three real ones, one of them through an original email found in the archive — a private source, showable on request, which no public search could have produced.

We measure production, not what the documentation says

The verification commands are included in the deliverable, so anyone can repeat them without us. When the document and the measurement do not agree, the measurement is right: while preparing this work, we found an internal document that declared a file about 16% smaller than it was, and an infrastructure diagram that described a server we had moved away from.

We declare what we could NOT measure

In our own accessibility and performance audit, the limitations section comes before the results and lists five things: render indicators the tool did not expose, keyboard activation the automation could not reproduce faithfully, the absence of screen reader tests, the inability to emulate the reduced motion preference, and the lack of field data. The conclusions drawn are marked as deductions, not observations.

We do not claim compliance levels we have not tested

The same audit contains no declared compliance level, because a complete audit requires testing with real screen readers, on real devices, with users — none of that had been done. What it does contain are individual findings, each with the relevant criterion, ordered so the work can be prioritised. Three blockers counted, the rest improvements.

We separate what can be published from what cannot

Technical fact from our own code: publishable, with the line. Actual project status: publishable, with the real reason, not the euphemism. Commercial result — clients, improvement percentages, volumes: not publishable without measurement and the client’s agreement. Comparison of the type “first” or “best”: not publishable without criterion and date. This grid applies before a line is written, not in proofreading.

We check consistency between what you publish and what the code does

The published policy and the implementation must not diverge, and divergence is hard to see from the inside. Examples from our own audit: the page promised IP address anonymisation, but the code sent it in full in a notification; the publicly declared retention period was not enforced by anything. The resulting rule: if a code change alters what is collected, where it goes, or how long it is kept, the published text changes at the same time.

The service, in detail

The data

What every system in the industry addresses

The classes of data held by beauty & wellness, with the basis for retention where the law provides it.

The client record and the procedure formula: Name, phone number, service history, product used, shade, stylist, price. It is the commercial core of the salon and what makes the second visit better than the first. The legal basis is performance of the contract or steps taken at the client’s request before the contract, and the issue is not legality, but the limit: the record grows by addition and never empties on its own.Keep: Related to the relationship with the client and the corresponding accounting obligations. The term is written explicitly by category, in the record of processing activities, or the criterion by which it is determined is communicated. A record kept ‘for any eventuality’ has no term, so it has no basis.SourceLaw 195/2024, art. 6 para. (1) lit. b), art. 5 para. (1) lit. c) and e), art. 30 para. (1) lit. f)
The answers to contraindication questions: Allergies, pregnancy, skin conditions, ongoing medication, recent procedures. This is information without which some procedures cannot be carried out safely, and it is health data. It is collected for a specific purpose — the decision on whether the procedure can be performed —, not for the client record in general, and the volume is reduced to what is necessary for that procedure: the correct question is "are you allergic to the substances in this procedure", not "what illnesses do you have".Keep: How long is necessary for the procedure to which it relates and for its safe repetition. It is deleted or re-evaluated when the client withdraws consent and there is no other basis. A contraindications questionnaire kept indefinitely becomes a medical record without being held by anyone bound by professional secrecy.SourceLaw 195/2024, art. 9 para. (1) and para. (2) lit. a), art. 5 para. (1) lit. c), art. 17 para. (1) lit. b), art. 30 para. (1) lit. f)
Before/after photographs: Two images of the same person, taken at different times, which exist precisely to show a difference. Their regime is not decided by format, but by what is visible: a hairstyle is an ordinary photo, treated skin is health data. Publication is a separate purpose from the internal documentation of the work and requires its own basis — it is not inherited from the fact that the photo was taken.Keep: For those published on the basis of consent: until withdrawal, and withdrawal must be as easy as giving consent. For those kept internally as evidence of the work: a written term, linked to the period during which the work may still be challenged. An album without a term is an album that is handed over together with the phone.SourceLaw 195/2024, art. 4 (the definition of “health data”), art. 9 para. (1) and para. (2) lit. a), art. 7 para. (3); Law 263/2005, art. 13 para. (10) — for the case of the medical and sanitary institution
The appointment calendar and the message thread: Time, the service, the specialist, the phone — and the conversation from which the appointment came, which usually contains more than the row in the diary. The messaging thread is the client’s second record and almost nobody declares it as such. If the diary sits in an online service, the provider of that service is a processor and needs a written contract with the subject, duration, nature, purpose, type of data and categories of data subjects, plus documented instructions.Keep: The booking history needs its own term, separate from the client record. Transfer to a provider in the European Economic Area does not require special authorisation; outside it, the transfers chapter applies in full.SourceLaw 195/2024, art. 6 para. (1) lit. b), art. 28 para. (1)–(3), art. 44 para. (2), art. 30 para. (1) lit. d) and f)
The deposit, payment data and the no-show record: The advance payment and the payment are governed by the contract. The record of those who did not show up is something else: it is a list built by the salon, about the behaviour of certain persons, which the salon uses to decide how to treat them in the future. When the basis is the salon's legitimate interest, the person has the right to object on personal grounds, and processing stops if the salon does not demonstrate legitimate and compelling overriding grounds.Keep: For payments, as much as accounting obligations require. For records of no-shows, a written and short term — a list without a term becomes a permanent blacklist, and that is hard to justify as proportionate.SourceLaw 195/2024, art. 6 para. (1) lit. b) and f), art. 21 para. (1), art. 5 para. (1) lit. e), art. 13 para. (1) lit. d)
The salon camera recordings: The cameras are installed for reasons unrelated to clients — theft, cash register security, disputes with staff — but they film people during a personal service, sometimes partially undressed. It is an area where the law requires special attention, and individual practices are not an area where the camera is installed “for order”. The persons being filmed must be informed at the time of collection, with the purpose, basis, recipients and retention period.Keep: The period is set by the salon and communicated at collection; when it cannot be given exactly, the criteria by which it is set are communicated. The factory setting of the recorder is not a term set by the operator.SourceLaw 195/2024, art. 6 para. (1) lit. f), art. 13 para. (1) and (2), art. 21 para. (1), art. 35 para. (3) lit. c)

Limbajul

The words people there use

An agent that says “programming” where the industry says otherwise is immediately heard as foreign. That is why vocabulary goes into configuration, not into the glossary at the end.

The client record: The record of a person’s treatments, kept so that a mistake is not repeated and so that the second visit starts where the first ended. In a salon it is a commercial item. In law it becomes two items the moment someone writes in it what they observed on the skin.
Contraindications: The reasons why a procedure cannot be performed now, for this person. It is the word used by the industry, not “medical history” and not “anamnesis”. A system that asks about contraindications is, in fact, asking a health question — whatever the field is labelled.
Sensitivity test: The test done before a procedure, usually twenty-four or forty-eight hours in advance, to see whether a reaction appears. It has a direct operational consequence: the appointment is not one, but two, and the second depends on the result of the first.
Formula: The exact combination used for a treatment — proportions, action time, product. It is the most valuable thing in the client file for the salon and the least sensitive for the client. It is worth keeping separate from everything else, precisely because the regimes differ.
Before/after: The pair of photographs that shows the result. It is the industry’s content unit and, at the same time, its risk unit. It is requested as such — the client understands “can I take a before/after photo?”, not “do you consent to the processing of the image”.
Window: A free slot in a specialist’s calendar, usually created by a late cancellation. The word is operational: whoever fills the gap wins the day. Any system built for a salon is judged by what it does with gaps, not by how nicely it displays services.
Neprezentare: The client did not come and did not cancel. The salon term, not “no-show” and not “cancellation”. The difference from cancellation is that it leaves no time to refill, so it is a direct loss — which is why deposits and lists appear.
Avans: The sum paid at booking, which makes the appointment firm. It is not a fee and it is not a penalty: it is part of the price of the service, paid in advance. The distinction matters, because a penalty requires a different contractual structure than an advance payment.
Maestru: The person who carries out the treatment. In many salons the client does not choose the salon, they choose the master, and leave with them if they move elsewhere. A system that treats specialists as interchangeable resources proposes times the client does not want.

Where it breaks down

What goes wrong when beauty & wellness are digitised in a hurry

The free field quietly changes the entire regime of the file

The salon builds a table with name, phone, service, price — an ordinary processing — and leaves a “notes” column at the end, because the master needs it. From the first note about a skin reaction, the table contains special categories: the exception from the record of processing activities for small firms falls away, the necessary basis changes, what can be done with export to another system changes. No one makes a decision. The column simply fills up.

The agreement for the photograph is tied to the possibility of being served

The reception form has one signature for everything: rules, contraindications, photographs, promotions. Without a signature, the appointment is not made. The structure seems efficient and is exactly what the law disqualifies: consent is not free when the provision of the service is conditional on an agreement for a processing that is not necessary for that service, and the request for consent must be presented in a form that clearly distinguishes it from the other aspects. The practical result is that the salon thinks it has consent and, at the first challenge, has nothing.

The messaging thread is the client’s second file and does not appear anywhere

Appointments come in through the messaging service of a social network, and there remain the photographs sent by the client, the description of the problem, sometimes documents. The conversation does not appear in the record of processing activities, does not appear in the information given to the client, has no deletion period and is accessible to anyone who has the salon phone unlocked. When the client asks for access to their data or for it to be erased, the salon responds from the table and forgets the thread — although the thread contains more than the table.

Withdrawal is requested more difficultly than consent was given

Consent was given by ticking a box on the phone, in ten seconds. Withdrawal is requested by written request, brought to the salon during working hours. The law explicitly requires withdrawal to be carried out with the same simplicity as consent was given, and this imbalance is easy to see from the outside and hard to defend. The side effect is commercial: a client who cannot leave a list simply does not complain, but stops responding altogether.

The salon grows into medical without moving its documents

A doctor is added one day a week, then two injectable procedures, then a device. The reception desk, calendar, chat and album remain the same. From the outside nothing has changed; legally, part of the activity has come under a sectoral law, with its own requirements on confidentiality, the person’s access to their own data and written consent for photography. Systems that do not distinguish between the two types of booking make it impossible to comply with both regimes, because they do not know which row is which.

Questions

What someone from beauty & wellness asks before buying software

A client asks in chat which procedure suits their skin. Can an automated assistant answer?

It may describe the services the salon provides and it may hand the conversation over to a person. It may not choose the procedure based on what the client describes about their skin, for two reasons that add up. First: the description is a health-related datum, and the salon does not have the medical exemption, so it would need explicit consent obtained beforehand, not a conversation that drifts there. Second: the person has the right not to be subject to a decision based solely on automated processing that significantly affects them, and decisions that fall within the exceptions cannot rely on special categories of data except through explicit consent or substantial public interest, with appropriate safeguards. An assistant that proposes times and a human who confirms suitability is an architecture that fits within the law.

Can we ask about allergies in chat, before booking?

Yes, but the question has to be built, not asked at random. Consent for a special category must be explicit and given for a specific purpose, and the request must be presented separately from the rest, in clear language. Practically: say why it is being asked, limit the question to the substances involved in the procedure discussed, and avoid the free-text field in which the client tells all their illnesses. The alternative that avoids the problem entirely is not to collect it in chat: the assistant books, and the contraindication question is asked at the salon, where the answer has an immediate purpose and a single recipient.

Can we publish the before/after photos on the salon’s social media?

With consent for the purpose of “publication”, distinct from consent to be photographed for the work file. Publication is not necessary for the service to be carried out, so the service cannot be made conditional on it — consent obtained that way is open to challenge. If the image shows a condition, it is a special category and consent must be explicit. And if the procedure was a medical act in a medical institution, sectoral law additionally requires written form. Three different requirements for the same photo, depending on what it shows and who carried out the procedure.

A client asks us to delete their photos published two years ago. Do we have to?

If the basis was consent and it is withdrawn, and no other basis exists, yes — and without undue delay. More than that: if the images have been made public, the controller must take reasonable steps, taking into account the technology available and the cost of implementation, to inform other controllers who are processing them about the request to erase links, copies or reproductions. That is the part salons do not anticipate: the photo has been reposted, and the obligation does not stop at the account itself. The deadline for replying to the request is at most one month, extendable by two, with the person informed within the first month.

Can we send an offer to those who have not come for a long time?

Yes, but that is direct marketing and is subject to its own rules, not reminder rules. The person has the right to object at any time to processing for this purpose, including profiling related to it, and on objection the processing for that purpose stops — without assessment, without balancing. The right must be brought explicitly to the person’s attention no later than at the first communication, presented clearly and separately from any other information. In practice this means the segmentation “who has not come for N months” must respect an objection list that is checked before sending, not after the first complaint.

We are a salon with five people. Do we need a record of processing and a data protection officer?

There are two questions with different answers. The record: the exception for under 250 employees falls away if the processing includes special categories or if it is not occasional, so a salon that asks about allergies and keeps a schedule owes it. The data protection officer: one is required when the main activities consist of large-scale processing of special categories or large-scale regular and systematic monitoring of persons. The main activity of a salon is the care service, not data processing, and “large scale” is the requirement that is usually not met. A salon may voluntarily designate an officer; that is not the same as being obliged to do so.

Our calendar is in an online service. Is that a problem?

Not in itself, but it creates two obligations that the salon has regardless of how good the provider is. First: the provider is a processor, and its processing must be regulated by a contract that sets out the subject matter, duration, nature and purpose of the processing, the type of data and categories of data subjects, with documented instructions, assumed confidentiality, a ban on subcontracting without written authorisation, assistance with client requests and deletion or return at the end. Second: if the data reaches outside the European Economic Area, the transfers chapter applies in full; for states in the European Economic Area, no special authorisations are required. The useful question for the provider is not “are you compliant”, but “where is the data kept and what do you sign”.

Can we put in a system that automatically refuses to book someone who has no-showed twice?

An automatic refusal to enter into a contractual relationship is the kind of decision that affects the person to a significant extent, and the person has the right not to be subject to a decision based solely on automated processing. Even in situations where such a decision is permitted, the controller must put in place measures that ensure at least human intervention, the expression of the person’s point of view, and the contesting of the decision. The construction that works is different and is also better commercially: the system flags it, asks for an advance payment instead of refusing, and a person decides exceptions. The difference between “booking is not possible” and “for this booking an advance payment is required” is the difference between an automated decision and a commercial rule.

We have added injectable procedures next to care services. Does anything change?

The regime changes, not the reception. From the moment the procedure is a medical intervention performed by a doctor or another medical worker, the patient rights law is added on top of the data protection rules: the confidentiality of information covered by medical secrecy, protected including after the person’s death; disclosure of confidential information only with explicit consent or where the law expressly requires it; the person’s unrestricted access to their own data, with the right to obtain a copy; and the prohibition on taking photographs or filming without written consent. At the same time, the medical exception to the prohibition on processing special categories becomes available, subject to professional secrecy. In practice, the same data, a different file and different forms — and the system that holds them must know which booking is which.

What we cannot claimNu punem în această pagină niciun rezultat propriu măsurat într-un salon și nu îl înlocuim cu o cifră de piață; ce am construit efectiv pentru industria asta e descris separat, în fișierul de soluție corespunzător, cu rezervele lui. Nu suntem juriști, nu emitem avize și nu ținem loc de consultanță juridică: aici sunt norme citate cu articol, nu analiza unui caz anume. Nu am putut verifica regimul sanitar sectorial al saloanelor și al centrelor de îngrijire — site-ul Agenției Naționale pentru Sănătate Publică a returnat 403 în ziua verificării, iar sursa oficială consolidată a legislației la fel; ce ține de norme de igienă, autorizare sanitară și produse cosmetice rămâne neverificat și nu e afirmat nicăieri mai sus. Nu am putut deschide textul Regulamentului (UE) 2016/679 în ziua verificării (provocare anti-bot), deci nu citez niciun considerent european — tot ce e scris despre fotografii și date biometrice vine din textul Legii 195/2024, citit direct. Nu verificăm lista tipurilor de operațiuni pentru care Centrul impune evaluarea impactului; când e publicată, ea decide, nu textul de față. Nu construim dispozitive medicale, nu certificăm aparatură și nu ne ocupăm de conformitatea actului medical. Nu avem un cod de conduită aprobat de Centru și nicio certificare în sensul legii. Nu numim niciun salon și nu publicăm nimic despre clienții cuiva.

The service, in detail What we actually built All scenarios

The service, appliedWe have not yet delivered exactly this combination. What you read above is the mechanism of our service, verifiable on its page, set alongside the rules that govern beauty & wellness — each with the article it comes from. What we have actually built sits on the service page and in the portfolio.

Sources 9 sources · verified on 2026-09-07

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