1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how we collect and process the personal data you provide when you:
• visit the salon;
• visit our website (regardless of where you visit it from);
• sign up to our loyalty card;
• email the salon to make a booking; or
• make an appointment by telephone.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
Hale Hair Boutique Limited is the data controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice). We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity: Hale Hair Boutique Limited
FAO: Data Privacy Manager
Email address: firstname.lastname@example.org
Postal address: 154 Merton Hall Road, SW19 3PZ
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 18 May 2018. We reserve the right to amend this privacy notice at any time. Any changes we may make to our notice in the future will be posted on this page. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
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.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Identity Data – includes first name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data – includes billing address, delivery address, email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address.
• Profile Data includes your purchases or orders made by you, points on your loyalty card, preferences, feedback and survey responses.
• Patch Test Data is patch test information.
• Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Except for Patch Test Data, we do not collect any special categories of personal data about you. Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and 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.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Transaction, Profile and Patch Test Data by visiting our salon or filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• purchase our products or services;
• make an appointment;
• sign up to our loyalty card;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
AUTOMATED TECHNOLOGIES OR INTERACTIONS.
We do not automatically collect Technical Data about your equipment, browsing actions and patterns.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data, where we need to perform the contract we are about to enter into or have entered into with you or where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, or where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than to send marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the details above.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
The purposes for which we use your data include services in respect of the following: to register you as a new customer, to provide you with the agreed services such as ensuring the Patch Test enables us to provide the appropriate service, manage payments or charges, asking you if you wish to participate in a survey, to enable you to partake in a prize draw, competition or complete a survey or to make suggestions and recommendations to you about goods or services that may be of interest to you.
The lawful basis for processing the personal data includes the performance of a contract with you or for our legitimate interest such as to study how customers use our products/services, to develop them and grow our business.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. To stop receiving any marketing communications from us, please follow the instructions in the ‘Opting out’ section below.
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 (we call this marketing).
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 when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third parties for marketing purposes.
• To stop receiving salon marketing communications by email please follow the unsubscribe link at the bottom of every email.
• To stop receiving salon marketing communications by SMS, just reply “STOP”.
• To unsubscribe from the newsletter, please follow the unsubscribe link at the bottom of every email.
• Visit your salon.
• Contact us on the details above.
Please note that you may have to unsubscribe from email and SMS marketing separately if you no longer wish to receive any marketing communications from us.
Please note that you may still receive some marketing messages for a short period after you have updated your marketing preferences, while our systems are fully updated.
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 us using the details above.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data, such as marketing platforms to send out marketing emails to you, for the purposes set out in paragraph 4 above. 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.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
7. 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, 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 will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
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.
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.
Your personal data will be held by the salon you have visited for as long as you remain an active client at that salon (we currently deem this to be two years from your last visit to the salon). If you have subscribed to our newsletter, your personal data will be held for as long as you remain a subscriber to the newsletter. If you choose to unsubscribe, then we will hold the record of your unsubscribe request to ensure that we comply with our legal obligations.
In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
• to request access to your personal data
• to request correction of your personal data
• to request erasure of your personal data
• to object to processing of your personal data
• to request restriction of processing your personal data
• to request transfer of your personal data
• to withdraw consent.
You can check and update your personal data each time you visit your salon. If you wish to make a complaint or you wish to exercise any of the rights set out above, please contact us using the details above.
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.