Laser Chic Limited Data Privacy & Cookie Notice
“We are committed to protecting your privacy and will ensure that any information you provide to us will be collected and used in accordance with the General Data Protection Regulation and the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003. We will not share your data with any third party except for administrative purposes relating to the services we provide and where we may be required to do so by law.” Laser Chic Limited
PURPOSE OF THIS PRIVACY NOTICE
Laser Chic Limited respects your privacy and is committed to protecting your personal data. This Privacy Notice explains what we do with your personal data, whether we are providing you with a service or you are visiting our website.
This privacy notice describes how Laser Chic Limited collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you and inform you about your privacy rights and how the law protects you.
This website is not intended for children and we do not knowingly collect data relating to children.
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. This privacy notice supplements the other notices and is not intended to override them.
Controller: Laser Chic Limited is the controller and responsible for your personal data (collectively referred to as Laser Chic Limited, “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact Details: Our full details are:
Full name and legal entity: Laser Chic Limited, trading as ‘Laser Chic’.
Phone number: 0161 445 6349
Email address: email@example.com
Postal address: Laser Chic Limited, 41 Barlow Moor Road, Didsbury, Manchester, M20 6TW
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 in October 2019 and historic versions can be obtained by contacting us.
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.
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 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.
WHAT KIND OF PERSONAL DATA DO WE COLLECT?
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).
In order to provide the best possible service to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you.
Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to enable us to offer you treatment options which are relevant to you. In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- 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, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- 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.
- Treatment Data includes information about the treatment you wish to receive from us. This information could include ‘health data’ which is a special category of personal data and therefore requires us to take extra steps to ensure it is adequately protected.
- Extra information that you choose to tell us; and CCTV footage if you attend our premises.
*Please note that the above list of categories of personal data we may collect is not exhaustive.
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.
With the exception of Treatment Data, we do not collect any other Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Other Users, such as Referees and Emergency Contacts: In order to provide Candidates and Clients with suitable options and opportunities, we require some basic background information (such as name, email address and telephone number). We only ask for very basic contact details, so that we can get in touch with you either for a reference or because you’ve been listed as an emergency contact for one of our Candidate or Client members.
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.
The Laser Chic website logs IP addresses and browser types to provide you with the best possible user experience and allow us insight into consumer behaviour. You can browse our site without entering any personal information, and therefore remain anonymous during your visit. However, the enquiry form asks for personal information such as name, postal address, email address and telephone number to enable us to send out the requested information, and make any future visits to our site easier.
HOW DO WE COLLECT YOUR PERSONAL DATA?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services; (through our online form or via our online booking)
- 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. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- analytics providers such as Google based inside the EU;
- advertising networks such as Adroll or Affilinet based; and
- search information providers such as Google or Bing based inside the EU.
HOW DO WE USE YOUR PERSONAL DATA?
The main reason for using your personal details is to help inform you of the services that we provide and to provide said service that may be suitable for you. The more information we have about you, your circumstances and your medical history, the more we can tailor our services to your requirements. We may also use your personal data for things like marketing, profiling and diversity monitoring. Where appropriate, we will seek your consent to undertake some of these activities.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct 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 Your Health Data: In light of the services which we provide to our customers, it will often be necessary for us to use information about your health. Even in the broadest sense of the word, ‘health’ information is a special category of personal data which requires us to have an additional lawful basis for using this information. Where we use information about your health for the purpose of providing our services to you (or in preparation for us to provide services to you), the additional lawful basis on which we shall rely will be that such use is necessary in order for us to provide you with health care or treatment.
Purposes For Which We Will Use Your Personal Data: We generally use Client data in three ways:
- Provision of Products & Services;
- Marketing Activities; and
- To help us to establish, exercise or defend legal claims.
Provision of Products & Services: Our main area of work is to provide non-invasive laser and skin treatment procedures. We’ve listed below various ways in which we may use and process your personal data for this purpose.
- Collecting your data from you and other sources;
- Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to procedures of interest;
- Providing you with our services and to facilitate the delivery of those services;
- Assessing data about you for procedures which we think may be suitable for you;
- Carrying out our obligations arising from any contracts entered into between us;
- Carrying out our obligations arising from any contracts entered into between Laser Chic Limited and third parties in relation to your procedures;
- Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you.
*Please note that this list is not exhaustive.
Marketing Activities: We may periodically send you information that we think you may find interesting. In particular, we may wish to use your data for the purposes listed below to:
- enable us to develop and market other products and services;
- market our full range of procedures to you;
*Please note that this list is not exhaustive.
We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we’ll ask for this via an opt-in or soft-opt-in.
Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a form fill on our website), and we are marketing other procedure-related services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other procedures complementary to you alongside the specific one you enquired for. For other types of e-marketing, we are required to obtain your explicit consent.
Promotional Offers From Us: We may use your Identity, Contact, Technical, Usage and 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 good 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.
Opting Out: You can ask us or third parties to stop sending you marketing messages at any time following the opt-out links on any marketing message sent to you or by Contacting us 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 product/service purchase, warranty registration, product/service experience or other transactions.
HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
How long we retain personal data depends on if the client has entered into a contract, the type of procedure contracted for and the level of recent substantial contact with or from the client.
When we refer to “substantial contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. We will also consider it substantial contact if you communicate with us about a procedure, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as substantial contact – this will only occur in cases where you click-through or reply directly.
Attended Procedures or Goods Purchased: In the event of a contract for procedure(s) existing we will delete your personal data from our systems if the last transaction date (appointment, payment or procedure) in relation to the contract is over 8 years old for treatment procedures and we have not had substantial contact with you for a period of one year.
Attended Consultation Only: In the event of a client having only attended for a consultation(s) in relation to the services we provide we will delete your personal data from our systems if the last consultation date is over 2 years old and we have not had substantial contact with you for a period of one year.
Expression of Interest Only: In the event of a client having only expressed an interest in our services and not attended any appointments in relation to the services we provide we will delete your personal data from our systems if the last substantial contact with us is not within a period of one year.
We will delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
HOW CAN YOU ACCESS, AMEND OR WITHDRAW THE PERSONAL DATA THAT WE STORE?
GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy.
This means that you retain various rights in respect of your data, even once you have given it to us. As detailed below.
To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled).
*Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Right to Object:
- If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
- This right enables you to object to us processing your personal data where we do so for one of the following four reasons:
- our legitimate interests;
- to enable us to perform a task in the public interest or exercise official authority;
- to send you direct marketing materials; and
- for scientific, historical, research, or statistical purposes.
- The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our Website Users and Clients. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
- We can show that we have compelling legitimate grounds for processing which overrides your interests; or
- We are processing your data for the establishment, exercise or defence of a legal claim.
- If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
Right to Withdraw Consent: Where we have obtained your consent to process your personal data for certain activities (for example, for the provision of a procedure), or consent to market to you, you may withdraw your consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
Data Access Request: You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
Right to Remove: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “remove” your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
Normally, the information must meet one of the following criteria:
- the data is no longer necessary for the purpose for which we originally collected and/or processed them;
- where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
- the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
- it is necessary for the data to be deleted in order for us to comply with our legal obligations as a data controller; or
- if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
We would only be entitled to refuse to comply with your request for one of the following reasons:
- to exercise the right of freedom of expression and information;
- to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
- for public health reasons in the public interest;
- for archival, research or statistical purposes; or
- to exercise or defend a legal claim.
When complying with a valid request for the removal of data we will take all reasonably practicable steps to delete the relevant data. If we have shared your personal data with third parties, we will notify them about the request for the removal of data unless this is impossible or involves disproportionate effort.
Right to Restrict Processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either:
- one of the circumstances listed below is resolved;
- you consent; or
- further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
- where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
- where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
- where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
- where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
Right to Rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
OUR LEGAL BASES FOR PROCESSING YOUR DATA
We use three of the legal bases set out in GDPR.
Contract: Article 6 (1) (b) of the GDPR says that we can process your data where it “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”. In plain language, this will apply if:
- you attend an appointment with us
- purchase goods from us
- agree to proceed with services provided by us.
Legitimate Interests: Article 6 (1) (f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.”
We don’t think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service, so everyone’s a winner! However, you do have the right to object to us processing your personal data on this basis.
Consent: In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent. Typically we would seek consent prior to the end of the legitimate interest period in order to continue processing data for direct marketing purposes.
Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” In plain language, this means that:
- you have to give us your consent freely, without us putting you under any type of pressure;
- you have to know what you are consenting to – so we’ll make sure we give you enough information;
- you should have control over which processing activities you consent to and which you don’t. We provide these finer controls within our privacy preference centre; and
- you need to take positive and affirmative action in giving us your consent – we’re likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.
We will keep records of the consents that you have given in this way.
As we have mentioned, you have the right to withdraw your consent to these activities.
WHAT ARE COOKIES AND HOW DO WE USE THEM?
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.
Most web browsers will accept cookies but if you would rather we didn’t collect data in this way you can choose to accept all or some, or reject cookies in your browser’s privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our website’s features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.
Cookies can also be categorised as follows:
- Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
- Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
- Functionality cookies: These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
KEEPING INFORMATION SECURE
We invest significant resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and so we cannot be held responsible for unauthorised or unintended access that is beyond our control.