By providing us with your personal information, you affirm to us that you are over 18 years of age.
The Cosmetic Skin Clinic is the information controller and we are responsible for your personal information (referred to as “we”, “us” or “our” in this privacy notice).
2. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
Personal information means any information capable of identifying an individual. It does not include anonymised information.
We may process certain types of personal information about you as follows:
- Identity Information may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
- Contact Information may include your home address, email address and telephone numbers.
- Financial Information may include your bank account and payment card details.
- Transaction Information may include details about payments between us and other details of purchases made by you.
- Technical Information may include internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Information may include purchases or orders, your interests, preferences, feedback and survey responses.
- Usage Information may include information about how you use our website, products and services.
- Marketing and Communications Information may include your preferences in receiving marketing communications from us and your communication preferences.
We may also process Aggregated Information from your personal information but this information does not reveal your identity and as such in itself is not personal information. An example of this is where we review your Usage Information to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Information with your personal information so that you can be identified from it, then it is treated as personal information.
We need to collect, what is considered, sensitive information about you in order to be able to provide the treatment you have requested and answer your questions.
We require your explicit consent for processing sensitive information, so when you submit your details, depending on the circumstances we may send you a further communication asking for you to confirm your consent to this processing.
Where we are required to collect personal information by law, or under the terms of the contract between us and you do not provide us with that information when requested, we may not be able to perform the contract (for example, to treat you). If you don’t provide us with the requested information, we may have to cancel the treatment you have an appointment forbut if we do, we will notify you at the time.
3. HOW WE COLLECT YOUR PERSONAL INFORMATION
We collect information about you through a variety of different methods including:
- Direct interactions: You may provide information by filling in forms on our website (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
- Make an appointment for treatment or a consultation;
- subscribe to our newsletter;
- request information or marketing be sent to you;
- enter a competition, prize draw, promotion or survey; or
- give us feedback.
- Third parties or publicly available sources: We may receive personal information about you from various third parties and public sources as set out below:
- analytics providers such as Google based outside the EU;
- review websites such as Trustpilot based inside the EEA; and
- search information providers such as Google based outside the EEA but behind the privacy shield.
4. HOW WE USE YOUR PERSONAL INFORMATION
We will only use your personal information when we have a legal basis for processing it. The most common way we use your personal information are:
- Where we need to perform the contract between us.
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal information, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at email@example.com.
Purposes for processing your personal information
Set out below is a description of the ways we intend to use your personal information and the legal grounds on which we will process that information. We have also explained what our legitimate interests are where relevant.
We may process your personal information for more than one lawful ground, depending on the specific purpose for which we are using your information. Please email us at firstname.lastname@example.org if you need details about the specific legal grounds we are relying on to process your personal information where more than one ground has been set out in the table below.
|Purpose/Activity||Type of information||Lawful basis for processing|
|To register you as a new customer||(a) Identity|
|Performance of a contract with you|
|To provide you with treatment including:|
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(f) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests to recover debts owed to us
|To manage our relationship with you which will include:|
(b) Asking you to leave a review or take a survey
(c) reminding you of appointment time and dates
(d) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity|
(e) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business
|To administer and protect our business and our site (including troubleshooting, information analysis, testing, system maintenance, support, reporting and hosting of information)||(a) Identity|
|(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise|
(b) Necessary to comply with a legal obligation
|To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising||(a) Identity|
(e) Marketing and Communications
|Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy|
|To use information analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical|
|Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity|
|Necessary for our legitimate interests to develop our products/services and grow our business|
You will receive marketing communications from us if you have:
- requested information from us or purchased goods or services from us; or
- if you provided us with your details and requested that we send you marketing communications; and
- in each case, you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at email@example.com at any time.
Where you opt out of receiving our marketing communications, this will not apply to personal information provided to us as a result of any treatment you have undertaken.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at firstname.lastname@example.org.
If we need to use your personal information for a purpose unrelated to the purpose for which we collected the information, we will notify you and we will explain the legal ground of processing.
We may process your personal information without your knowledge or consent where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL INFORMATION
We may have to share your personal information with the parties set out below for the purposes set out in the table in paragraph 4 above:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- Third parties to whom we may sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your information to respect the security of your personal information and to treat it in accordance with the law. We only allow such third parties to process your personal information for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal information, so European data protection law has prohibited transfers of personal information outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal information will involve a transfer of information outside the EEA.
Whenever we transfer your personal information out of the EEA, we do our best to ensure a similar degree of security of information by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal information the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer information to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal information shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.
7. INFORMATION SECURITY
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know such information. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. INFORMATION RETENTION
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Information) for seven years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your information: see below for further information.
In some circumstances we may anonymise your personal information (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 about how the personal information you provide can be used. These are:
- Transparency over how we use your personal information (right to be informed).
- The ability to request a copy of the information we hold about you, which will be provided to you within one month (right of access).
- Update or amend the information we hold about you if it is wrong (right of rectification).
- Ask us to stop using your information (right to restrict processing).
- Ask us to remove your personal information from our records (right to be ‘forgotten’).
- Object to the processing of your information for marketing purposes (right to object).
- Obtain and reuse your personal information for your own purposes (right to data portability).
- Not be subject to a decision when it is based on automated processing (automated decision making and profiling).
If you would like to know more about your rights under the data protection law, you can find out more at the Information Commissioners Office website.
Remember, you can change the way you hear from us or withdraw your permission for us to processing your personal information at any time by using the form on our ‘Contact Us‘ page or by using our online membership Portal.
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org
You will not have to pay a fee to access your personal information (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 may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.
We try to respond to all legitimate requests within one month. Occasionally it may 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. THIRD-PARTY LINKS
This website 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 information 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 notice of every website you visit.
12. CONTACT DETAILS
Our full details are:
Name: The Cosmetic Skin Clinic.
Email address: email@example.com
Postal address: 84 Rogers Lane, Stoke Poges, Buckinghamshire, SL2 4LF
Telephone number: +44 1753 646 660
If you are not happy with any aspect of how we collect and use your information, please contact us so we can investigate and try to resolve the issue for you. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for information protection issues (www.ico.org.uk).
It is essential that the information we hold about you is accurate and up to date. Please let us know if your contact details change.