AT Skin and Laser & Forever Young (“We”) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example, name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
- Who are we & important information
AT Skin and Laser Ltd / Forever Young is the data controller. This means we decide how your personal data is processed and for what purposes.
Our contact details are:
AT Skin and Laser Ltd & Forever Young Ltd.
11-13 Station Road
Marlow. Bucks. SL7 1NG
For all data matters contact Alicia Trenchard on
0330 223 1009
Third-party links outside of our control
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 data 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.
- The personal data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes: first name/last name/ username/marital status/ title/date of birth/gender.
- Contact Data includes: billing address/delivery address/email address/ telephone numbers.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
- The purpose(s) of processing your personal data
We use your personal data for the following purposes:
- Meet our obligations under relevant legislations
- To enter into a contract with you (providing goods & services)
- To maintain our own accounts and records
- To meet internal audit requirements
- Research and development opportunities
- Periodically send promotional emails about new products, events, special offers or other information which we believe may be of interest.
5. The categories of personal data concerned and how we collect your data
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
- Personal data: Id Number, Photo, name, address, email, phone number, financial and credit card information
- Special categories of data: Health and Medical History
We have obtained your personal data from you the ‘data subject’ when you either complete our client registration or consultation form, correspondence with us by phone, email or otherwise when you book an appointment
6. What is our legal basis for processing your personal data?
- Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
- Special categories of personal data (article 9 of GDPR)
Our lawful basis for processing your special categories of data:
More information on lawful processing can be found on the ICO website.
Failure to provide us with your personal data
You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so will have the following consequences:
Where we need to collect your personal data by law, or under the terms of a contract we have with you and if you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by emailing us on email@example.com at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
What are cookies?
Cookies are small text files that are sent to and stored on your computer for accessing the internet, whenever you visit a website. These cookies do not collect any personal data stored on your computer’s hard drive.
How to manage your cookies
To find out more about cookies at www.allaboutcookies.org
8. Change of purpose
We will only use your personal data 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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Alicia Trenchard on 0330 223 1009 or email: firstname.lastname@example.org
If we need to use your personal data for an unrelated purpose, we will notify you prior to commencing and will explain the legal basis which allows us to do so.
9. Sharing your personal data
Your personal data will be treated as strictly confidential and will be shared internally with staff who require access necessary for the performance of their role and with Third Parties relevant to the provision of our services.
Third parties relevant to the provision of our services parties set out below:
External Third Parties Service such as:
- We currently do not use [acting as processors] any IT company to provide IT support and maintenance for AT Skin and Laser Ltd & Forever Young Ltd.
- HAMBRAND Technologies Ltd trading as Pabau, our Software management system (ACTING AS PROCESSORS) a company based in the 27 Cuthberts St. Bedford, Beds, MK40 3JG who provide AT Skin and Laser Ltd & Forever Young Ltd support, maintenance and administration services relating to the database.
- Professional advisers [acting as processors or joint controllers] including Doctors, lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, Banking, Legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities [acting as processors or joint controllers] based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
10. Transfer of Data Abroad
we do not transfer personal data outside the eea.
11. Automated Decision Making
WE DO NOT USE ANY FORM OF AUTOMATED DECISION MAKING IN OUR BUSINESS
12. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
13. Data Retention
We will only retain your personal data 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. However, in case of any legal claim or complaint length of time data retained will be dependent on dispute/legal action and will remain open till case/legal action closed.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we must keep basic information about our clients including contact, identity, financial and transaction data for 6 years after they cease being clients for Tax purposes.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (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.
If you wish to see our Retention Policy please contact Alicia Trenchard on 0330 223 1009
or email: email@example.com
14. Your legal rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact Alicia Trechard on 0330 223 1009 alternatively email Alicia on: firstname.lastname@example.org
No fee required – with some exceptions
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.
Time limit to respond
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.
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
16. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact Alicia Trenchard on enter 0330 223 1009
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.