Privacy Notice
Welcome to the The Spa at Laceby
Manor privacy notice.
The Spa at Laceby Manor 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 when you visit our website (regardless of where
you visit it from), use our mobile application software as either a customer
user or a beauty or wellness therapist user or interact with us on social media
and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a
layered format so you can click through to the specific areas set out below.
Please also use the Glossary to understand the meaning of some of the
terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
11. COOKIE
POLICY
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you
information on how The Spa at Laceby Manor collects and processes your personal data
through your use of this mobile and web application service (“app”) as either a
customer user or a beauty or wellness therapist user, including any data you
may provide through this website when you request or perform a treatment,
register and use our app, sign up to our newsletter or email subscription,
register to attend one of our events, interact with us on social media or take
part in a competition or survey.
This app 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. If you are a beauty or wellness therapist user, we
will also provide to you a copy of our staff and contractor privacy notice
because you may on occasion act as our contractor for B2B events separate to
the app or there may be other occasions such as in respect of legal or tax
processes in which we may need to process other types of data about you than is
set out in this data privacy notice.
Controller
The Spa at Laceby Manor is the
controller and responsible for your personal data (collectively referred to as
“we”, “us” or “our” in this privacy notice).
We have appointed a data protection officer (DPO) 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 DPO using the
details set out below.
Contact details
Our full details are:
Full name of legal entity: The Spa at
Laceby Manor , Company registration
number: 09470015
Name or title of DPO: Head of People
& Culture
Email address: info@lacebymanor.co.uk
Postal address: Barton Street, Laceby, DN37 7LD
Telephone number: 01472 873468
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
August 2020.
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 app 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 app, we encourage you to read
the privacy notice of every website you visit or app you use.
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, maiden
name, last name, username or similar identifier, marital status, title, date of
birth and gender.
· Special Category Personal Data includes details about your health
(or race or religion if ever relevant to treatments requested or performed by
you)
· Contact Data includes billing address,
address at which you want the treatment to take place, email address and
telephone numbers.
· Financial Data includes bank account (or
similar, such as Paypal, as might be relevant from time to time) and payment
card details.
· Transaction Data includes details about payments
to and from you as either a customer user or beauty or wellness therapist user,
and as a customer user other details of services or products you have purchased
from us or the beauty or wellness therapists.
· 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 app.
· Profile Data includes your username and
password, purchases or orders made by you or fulfilled by you for customer
users, your interests, preferences, social media interaction, feedback and
survey responses.
· Usage Data includes information about how
you use our website, mobile application and services and as beauty or wellness
therapists about how you perform services for your customer user clients
through our app.
· 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.
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 (such as withdrawing your registration as a customer or beauty
or wellness therapist user, although that should only be in rare cases), 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,
Special Category, 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:
· make or accept an appointment;
· purchase or sign up to our services;
· complete our pre-treatment questionnaires;
· register to attend an event;
· subscribe to our publications;
· request marketing to be sent to you;
· enter a competition, promotion or survey; or
· give us some feedback directly through our website or app or through
the beauty or wellness therapist users.
Automated technologies or
interactions. As you interact with our website and app, 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. Please see our cookie policy for
further details.
Third parties or publicly available
sources. We may receive personal data about you from various third parties and
public sources as set out below:
· Technical Data from analytics providers such as Google based outside the
EU;
· Contact, Financial or Transaction Data from providers of technical,
payment and delivery services such as:
o Stripe Inc is a global company we use to process online payments to the
beauty or wellness therapists and so that we can receive our commission. Their
privacy policy can be accessed here https://stripe.com/gb/privacy
o Mixpanel Inc is a global company which we use to process bookings
between customer users and beauty or wellness therapist users through our app.
Their privacy policy can be accessed here https://mixpanel.com/legal/privacy-policy/
o Mailchimp is a global company which we use for email marketing. Their
privacy policy can be accessed here: https://mailchimp.com/legal/privacy/
o Customer.io is a global company which we use for email marketing. Their
privacy policy can be accessed here: https://customer.io/legal/privacy-policy/
o Mention Me is a global company which we use for our refer-a-friend
programme and related services. Their privacy policy can be accessed
here: https://mention-me.com/help/privacy_policy
o Timely is a global company which we use to process bookings between
customer users and beauty or wellness therapist users through our website.
Their privacy policy can be accessed here https://www.gettimely.com/support/privacy/
o Rakuten Advertising is a global company we advertise with. Their privacy
policy can be accessed here https://go.rakutenadvertising.com/hubfs/Services-Privacy-Policy-English.pdf
· Identity and Contact Data from publicly availably sources such as
Companies House and the Electoral Register or beauty or wellness therapists’
business websites based inside the EU.
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 in the
following circumstances:
· Where we need to perform the contract we are about to enter into or have
entered into with you.
· 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.
· 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 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.
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 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
Type
of data
Lawful
basis for processing including basis of legitimate interest
To
register you as a new customer or beauty or wellness therapist
(a)
Identity (b) Contact (c) Special Category (d) Financial (e) Profile (f)
Marketing and Communications
Performance
of a contract with you
To
process and deliver your order or allow you to deliver your service to your
customer user client, including: (a) Allocating the correct therapist to
provide the treatment to you as the customer user and introducing you to your
customer user client as the beauty or wellness therapist user (b) Allowing
the beauty or wellness therapist to attend your premises (c) Allowing a
beauty or wellness therapist to determine the best way to provide any
treatment to customer users or which products are most suitable for customer
users (d) Manage payments, fees and charges (e) Collect and recover money owed
to us/or the beauty or wellness therapists and/or customer users (such as for
a refund)
(a)
Identity (b) Contact (c) Special Category (c) Financial (d) Transaction (e)
Marketing and Communications (f) Usage
(a)
Performance of a contract with you (b) Necessary for our legitimate interests
(to recover debts due to us or for addressing safety issues for both customer
users and beauty or wellness therapist users)
To
manage our relationship with you which will include: (a) Notifying you about
changes to our terms or privacy policy (b) Asking you to leave a review or
take a survey
(a)
Identity (b) Contact (c) Profile (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 (b) Contact (c) Profile (d) Usage (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 this website and mobile application (including
troubleshooting, data analysis, testing, system maintenance, support,
reporting and hosting of data)
(a)
Identity (b) Contact (c) Technical (d) Usage
(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 and mobile application content and advertisements to
you and measure or understand the effectiveness of the advertising we serve
to you
(a)
Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
(f) 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, mobile application, products/services,
marketing, customer relationships and experiences
(a)
Technical (b) Usage
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
(a)
Identity (b) Contact (c) Technical (d) Usage (e) 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.
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.
Third-party marketing
We will get your express opt-in
consent before we share your personal data with any third-party company for
marketing purposes. If we do ask for your consent it will only be in
relation to carefully selected third-parties who we think may be of interest to
you due to their close connection with the beauty industry.
Opting out
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 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 service purchase, service experience or other transaction.
Cookies
You can set your browser to refuse
all or some browser cookies, or to alert you when websites set or access
cookies. If you disable or refuse cookies, please note that some parts of this
website may become inaccessible or not function properly. For more information
about the cookies we use, please see our Cookie Policy at the bottom of this
page.
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.
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.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 with the parties set out below for the purposes set out in the table in
paragraph 4 above.
· External Third Parties as set out in the Glossary
· 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.
6. International transfers
Many of our external third parties are based outside the European
Economic Area (EEA) so their processing of your
personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal
data out of the EEA, we ensure a similar degree of protection is afforded to it
by ensuring at least one of the following safeguards is implemented:
· We will only transfer your personal data to countries that have been
deemed to provide an adequate level of protection for personal data by the
European Commission.
· Where we use certain service providers, we may use specific contracts
approved by the European Commission which give personal data the same
protection it has in Europe.
· Where we use providers based in the US, we may transfer data to them if
they are part of the Privacy Shield which requires them to provide similar
protection to personal data shared between the Europe and the US.
Please contact us if
you want further information on the specific mechanism used by us when
transferring your personal data out of the 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, 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.
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.
By law we have to keep basic
information about our customers (including Contact, Identity, Financial and
Transaction Data) for six years after they cease being customers for tax
purposes.
In some circumstances you can ask us to delete your data: see Request erasure 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.
9. Your legal rights
Under certain circumstances, you have
rights under data protection laws in relation to your personal data. Full
details on these are found in the Glossary.
· Request
access to your personal data.
· Request
correction of your personal data.
· Request
erasure of your personal data.
· Object
to processing of your personal data.
· Request
restriction of processing your personal data.
· Request
transfer of your personal data.
· Right
to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
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 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. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in
conducting and managing our business to enable us to give you the best
service/product and the best and most secure experience. We make sure we
consider and balance any potential impact on you (both positive and negative)
and your rights before we process your personal data for our legitimate
interests. We do not use your personal data for activities where our interests
are overridden by the impact on you (unless we have your consent or are
otherwise required or permitted to by law). You can obtain further information
about how we assess our legitimate interests against any potential impact on
you in respect of specific activities by contacting us.
Performance of Contract means processing your data
where it is necessary for the performance of a contract to which you are a
party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory
obligation means processing your personal data where it is necessary for compliance
with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
External Third Parties
· Service providers acting as processors who provide IT and system
administration services.
· Professional advisers acting as processors or joint controllers
including lawyers, bankers, auditors and insurers 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.
· Stripe Inc is a global company we use to process your online payments to
us. Their privacy policy can be accessed here https://stripe.com/gb/privacy
· Mixpanel Inc is a global company which we use to process your booking
with us if you do so through our app. Their privacy policy can be accessed
here https://mixpanel.com/legal/privacy-policy/
· Mailchimp is a global company which we use for email marketing. Their
privacy policy can be accessed here: https://mailchimp.com/legal/privacy/
· Customer.io is a global company which we use for email marketing. Their
privacy policy can be accessed here: https://customer.io/legal/privacy-policy/
· Mention Me is a global company which we use for our refer-a-friend
programme and related services. Their privacy policy can be accessed
here: https://mention-me.com/help/privacy_policy
· Timely is a global company which we use to process your booking with us
if you do so through our website. Their privacy policy can be accessed
here https://www.gettimely.com/support/privacy/
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 restriction of processing of your personal data. This
enables you to ask us to suspend the processing of your personal data in the
following scenarios: (a) if you want us to establish the data’s accuracy; (b)
where our use of the data is unlawful but you do not want us to erase it; (c)
where you need us to hold the data even if we no longer require it as you need
it to establish, exercise or defend legal claims; or (d) you have objected to
our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
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.
11. Cookie Policy
Our website uses cookies. A cookie is
a small text file which is stored on your computer, tablet or phone when you
visit a website. These cookies allow us to distinguish you from other users of
our website. This helps us to provide you with a good experience when you browse
our website and also allows us to improve our website.
There are two main types of cookie:
· session cookies—these are deleted when you finish browsing a website and
are not stored on your computer longer than this.
· persistent cookies—these are stored on your computer after you have
finished using a website so that the website provider can remember your
preferences the next time you use it.
Cookies can be set by the website you
have browsed, ie the website displayed in the uniform resource locator (URL) window.
These are called first party cookies. Third party cookies are set by a website
other than the one you are browsing.
To find out more about cookies, including how to see what cookies have
been set and how to manage and delete them, visit www.allaboutcookies.org.
How do we use cookies?
· To estimate our audience size and usage pattern;
· To store information about your preferences, and so allow us to
customise our site according to your individual interests;
· To speed up your searches;
· To recognise you when you return to our site.
Consent
If you continue to use our Site we
will assume that you are happy to receive all cookies from our website.
However, if you would prefer to change your cookie settings, you can do so at
any time—see below ‘Controlling our use of cookies’.
Controlling our use of cookies
Most browsers automatically accept
cookies unless you change your internet browser settings. If you wish to
restrict, block or delete the cookies which are set by any websites, you can
generally do this through your browser settings. These settings are usually
found in the ‘options’ or ‘preferences’ menu of your internet browser.
If you set your internet browser
preferences to block all cookies, you may not be able to access all or parts of
our site.
If you delete cookies relating to
this website we will not remember things about you, including your cookie
preferences, and you will be treated as a first-time visitor the next time you
visit the site.
If you have any questions or comments regarding our Cookies Policy,
please contact us.