The following privacy notice outlines how Beaute 21 Ltd T/A Beauté 21 (‘we’ or ‘us’ or ‘our’) gathers, processes, and protects your personal data. Beauté 21 is a Beauty salon and retail shop that provides services including treatments and retail of associated products.
Personal data collected
The personal data that we collect is:
- Email Address
- Date of Birth
- Phone number
- Consultation forms
- Health information
- Records of Patch Testing
- Appointment data & associated notes
- Purchases data & associated notes
- Gift Voucher records and contact details of recipient
- Payment card details (for online appointment deposits, collected and stored by a GDPR compliant third party via Phorest, no access to these details are available at the salon)
- Marketing preferences
- Client correspondence
- CCTV images (of Beauté 21 premises & vicinity)
Purpose and Legal Basis for Processing Your Data
We take your privacy seriously and we will never sell or rent your personal data to any third-party. We need to obtain and process your personal data to provide you with our products and services, to ensure that clients are safe and able to have a specific treatment, and to fulfil our business and legal obligations. We will never collect any personal information from you that we do not need or retain any data that is no longer necessary for the purposes specified in this notice. Where we request sensitive personal data from you (i.e. health or medical data), the reason(s) for the request will be clearly given along with the purposes of the processing. Explicit consent through a signature will always be required for us to obtain and process your health information. Your personal data is collected and processed for the following reasons:
- To enable us to sell appropriate products or services
- Through legitimate interest to engage in communication with you including; confirmation and reminders of appointments, and requests to cancel or change bookings.
- Health information is collected to enable us to perform the agreed services appropriately, to potentially highlight areas that products and services may cause issues to clients because of their health and provide industry standard advice.
- As part of our legal obligation for business accounting, tax and insurance purposes.
- As required by law or to respond to legal process.
- To share offers, promotions and information for you, usually in the form of our monthly newsletter.
Who is processing my data?
All data is processed and secured via our salon software provider; Phorest, 9 Anglesea Row, Smithfield, Dublin, D07 W5NE, Ireland, the data controller for the purposes laid out in this privacy notice. Phorest, acts as data processor on behalf of Beauté 21 and have access to personal information only in cases that we require customer support or troubleshooting. Further, they must process the personal information in accordance with this Privacy Notice and as permitted by applicable data protection laws.
Your rights as the individual
If your personal data is held by Beauté 21, you hold particular rights over it. Where you have provided consent for us to contact you as part of our marketing services, you have the right to modify or withdraw your consent at any time by using the unsubscribe option accompanied with all of our direct marketing or by contacting the Beauté 21 Data Protection Officer. You also have the right:
- To be informed of how your personal data will be used before it is collected.
- To access your personal data and to receive information on how your information is used after it has been gathered.
- To have personal data corrected if it is incomplete, inaccurate or out-of-date.
- To request the removal or deletion of personal data where there is no compelling reason for its continued processing.
- To restrict processing, to ‘block’ processing of your personal data.
- To data portability, having your data moved, copied or transferred from Beauté 21 in an easily readable format.
- To object to direct marketing from us.
Special categories of personal data collected
Health questions are asked in our clients consent forms to potentially highlight treatments that may have a negative effect on your health due to medication you are taking or a condition you have. We will always ask for consent prior to gathering and processing this information. At any time after giving consent, you can withdraw you consent, subject to legal, insurance and contractual restrictions (see more on ‘your rights as an individual’). Your privacy is very important to us and this information is only used for determining your suitability for the treatment.
Process of collection
Your personal data is collected when you provide it to us through Phorest software, our website, over the phone, at our reception, by email, our salon app, social media, in writing or any other means by which you provide it to us. Information is stored using the Phorest software platform. Phorest gives consumers access to information about their account and bookings through Phorest software, for the limited purpose of viewing and updating that information.
We do not collect the personal data of children under the age of 16 without parental or guardian consent. If you believe that we hold any information from or about a child under age 16, please contact us and if we cannot immediately obtain appropriate parental or guardian consent, will remove the personal data from storage.
Your personal data is shared only with Phorest representatives in cases that customer support and troubleshooting is required for the salon. Phorest do not share your personal information with any third-party without your prior consent, other than those already disclosed in this privacy notice or as part of our legal obligations under the relevant data protection laws.
Use of Data Processors
Data processors are third parties who provide some elements of Phorest’s business services for Beauté 21. Where they use a third-party, they have strict agreements in place governing the processing of your personal data, on which no action can be taken without instruction from us. The third-parties with whom they work will never share or disclose your personal information and will hold it securely at all times. We utilise software provided by Phorest to manage our business, including but not limited to accepting bookings, organising appointments, taking payments etc.
How Long Do We Keep Your Data?
We retain your personal data for as long as necessary to provide you with our services as our client. We are required under tax laws to keep your personal data for a minimum of 7 years. Health and Safety records will be retained for 10 years and where we have your consent for marketing purposes, we will retain the minimum required data until you notify us that you no longer wish to receive such information. The criteria for which we would continue to process your personal information includes:
- Where there is a legal basis, obligation or legitimate interest to continuing processing your personal information
- Where processing is necessary for the establishment, exercise or defence of legal claims
Cookies (if applicable)
Transfers of personal information
When personal data of persons located in the EU is processed through our Phorest software, all of it is held within the EU. Your information is processed by the Phorest software and stored in the Amazon Web Services cloud infrastructure. During this process your data is encrypted in transit and at rest.
Consequences of not providing your personal information to Beauté 21
In the event that you want to purchase a product or service from Beauté 21, certain personal information is required to enter into a contract with you. We will not be able to enter into a contract with you to fulfil an attempt to purchase a product or service if you do not provide your personal information. As noted in this privacy statement, we are processing your personal data to comply with legal and statutory obligations and in the performance of a contract. You can always choose not to provide personal information; however, we will be unable to provide certain products, services and treatments in these instances.
Safeguarding your Personal Data
Appropriate measures are taken to protect your personal data from access from unauthorized persons or inappropriate access, internal or external. Our connection to the Phorest system uses a HTTP Secure communication protocol and TLS security. This means all information passed to the Phorest system is encrypted during data input and transfer to the cloud. Any paper files recording your personal data (if applicable) are held in a locked filing cabinet or safe which can only be accessed by authorised personnel in the salon. Employees are only assigned specific access rights necessitated by their role and can only access the salon software and tablets with the PIN number assigned to them by the management of the salon.
Health data collection
Where we collect information about your health or medical circumstances, we have a legal obligation to collect this information for health and safety and insurance purposes and only do so with your explicit consent. The privacy and security of your data is very important to us and we will only use health related information for the purposes described on this form and in our Privacy notice. You will be asked to sign to confirm your consent at each appointment via our passworded salon tablets.
Promotions & Offers
From time to time we like to contact you via email or text with details of our special offers and other products and services that we provide, this is usually in the form of our monthly newsletter generated by our Phorest Software . You will be asked to consent to us contacting you for this purpose. You can opt out of this service at anytime by following the link on all of our email correspondence or by emailing firstname.lastname@example.org
We hope that Emma Oliver can resolve any query or concern you raise about our use of your information, please allow us the opportunity to assist you with your query by emailing email@example.com or by writing to Emma Oliver, Beaute 21, 21 The Weir, Hessle. HU13 0SB before raising any complaint with Data Protection authorities ico.org.uk/concerns/
Emma Oliver, Owner
16th May 2018