The GDPR (General Data Protection Regulation) is a new regulation which takes effect across the EU on 25 May 2018.
Individuals have more rights when it comes to their own personal data and businesses consequently have more responsibility and accountability for how they use and protect that data.
What does it mean for Agota`s Beauty and for you?
It means we all need to take extra care when collecting and processing the personal data of our customers (emails, phone numbers etc) so that we can provide customers with the assurances they may want about how their data is being protected and used.
Why is it so important that we comply with GDPR?
We risk damaging our reputation and losing customers if we do not take this seriously. This presents a great opportunity for us to show our customers that we are responsible and trustworthy. By taking GDPR seriously, we will build even stronger relationships with our customers. The stakes have been raised. Maximum fines for non-compliance are the greater of €20 million or 4% of worldwide revenue. Agota`s Beauty is 100% committed to GDPR compliance. We dedicated and have been preparing for over a year now, to comply with GDPR.
Agota`s Beauty Respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
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 our salons; visit our websites (regardless of where you visit it from); sign up to our rewards card; register for online bookings; make an appointment by telephone; sign up to the Agota`s Beauty newsletter Access to 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 Agota`s Beauty 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 Salon manager who is also responsible for data privacy and 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 Salon manager using the details set out below.
CONTACT US Our full details are:
Full name of Business: Agota`s Beauty
FAO: Salon Manager
Email address: firstname.lastname@example.org
Postal address: Agota`s Beauty
339 Brockles Mead
Telephone number: +44 7366015827
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 1/10/2019.
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 and, where appropriate, notified to you by email or SMS.
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 (www.agotabeauty.co.uk) 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 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, 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. Profile Data includes your username and password, purchases or orders made by you, points on your rewards card, preferences, feedback and survey responses. Allergy Test Data includes allergy test information and details of any medical conditions that might affect services 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. 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.
Except for health information and Allergy Test Data, we do not collect any special categories of personal data about you. Not 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.
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 Allergy Test Data by visiting our salons 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 rewards 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. 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.
Third parties. We may receive personal data about you from various third parties as set out below:
Technical Data from analytics providers such as Google; Identity, Contact, Technical, Profile, Usage and Transaction Data from providers of technical, payment and delivery services. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the details above if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity and Types of Data Used Lawful basis for processing including basis of legitimate interest To register you as a new customer
Data: Identity, Contact and Allergy Test
Performance of a contract with youTo provide you with your order or service which includes:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
Data: Identity, Contact, Allergy Test, Profile and Transaction
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(c) Necessary for your legitimate interests (to ensure that we provide you with a safe service)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a survey
Data: Identity, Contact, Profile, Transaction and 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
Data: Identity, Contact, Profile, Usage and 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 website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Data: Identity, Contact and Technical
(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 website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Data: Identity, Contact, Profile, Usage, Marketing and Communications, Technical
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 data analytics to improve our website, products/services, marketing, customer relationships and experiences
Data: Technical, Usage and Profile
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website 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
Data: Identity, Contact, Usage, Technical and Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)
MARKETING 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 Notify this to our customer service.
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.
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.
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.
Details of retention periods for different aspects of your personal data are as follows:
Your personal data will be held by our 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). After you cease to be an active client, we will still retain some of your details to ensure that we comply with our legal obligations and legitimate business interests. 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.
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.
YOUR LEGAL RIGHTS Under certain circumstances, you have the following rights under data protection laws in relation to your personal data (further details of which are contained in the Glossary):
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.
NO FEE USUALLY REQUIRED 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 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 3 to 5 working days. 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.
YOUR LEGAL RIGHTS You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.