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Privacy Notice - GDPR
Clinica Aesthetics
info@clinica-aesthetics.uk
Privacy Policy
Clinica Aesthetics is committed to respecting your privacy and this policy is designed to tell you about our practices regarding the collection, use and disclosure of information that you may provide via our website, other media portals and in person. Any personal information we collect from you will only be used in accordance with this policy. Please read it carefully so that you understand our views and practices.
Your consent
For the purpose of the relevant General Data Protection Regulations, Clinica Aesthetics, is the data controller and responsible for your personal data, collectively referred to as ‘we’, ‘us’ or ‘our’ in this privacy policy.
When you do business with us; register with our website for the purpose of obtaining services and/or goods (including subscriptions and email notifications and/or newsletters); participate in discussion boards or other social media functions, on the website; or other information on the website; or enter a survey, competition or prize draw; we will collect some or all of the following personal information from you:
• financial and credit card information;
• personal description and photograph;
• information about your computer or other electronic device, such as your IP address or Google analytics, and about your visits to, and use, of our
website. Please see our Cookies policy for further information;
• information relating to transactions carried out between you and us, on or in relation to this website; and any other information that you choose to
send to us
You can visit the Clinica Aesthetics website without registering with us, however you may be required to register or log in to view certain pages and/or information.
We may request additional information from you, for example when we conduct a survey or you enter a competition or prize draw. When additional information is requested, we will let you know at the time of collection how we intend to use it.
We do not store credit card details nor do we share customer details with any third parties.How we will use the information about you
We use your information held in the following ways:
• to administer the website;• to maintain a database of our customers and registered users;
• to enable you to use the services available on the website;
• to process orders and supply you with products and services purchased via the website;
• to book you on a treatment course;
• to track users on our website;
• to collect payments from you;
• to contact you or send you information directly relating to your order, booking, any survey or competition, or use of the website;
• to add you to relevant mailing lists and send you subscriptions, email notifications and/or newsletters which you have specifically requested;
• to send you marketing communications relating to Clinica Aesthetics, for example about our events and services, which we think may be of interest
to you or where you have specifically agreed to this, by email or similar technology (but you can unsubscribe from these communications at any time
by changing your subscription preferences in the My Profile section of the website);
• to deal with enquiries and complaints made by or about you relating to the website any products or services;• to provide feedback to any of our business partners, agents, suppliers and sub- contractors; and to keep the website secure and prevent fraud.
We may process your personal data for more than one of the following lawful grounds depending on the specific purpose for which we are using your data:
• because the processing is necessary for the purposes of our legitimate interests as a data controller in that we need to;
• where we need to comply with a legal or regulatory obligation.
Please contact us if you need details about the specific legal ground we are relying on to process your personal data for each of the information we hold about you.
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 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.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
• Promotional offers from us. We may use the information we collect (detailed above) 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.
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.
• Opting out. You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or
unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by
contacting us at any time.
We may share your personal information with our employees and any member of our group, (which includes any subsidiaries and holding companies, as defined in section 1159 of the UK Companies Act 2006), for the purposes set in this policy. We may share your information with selected third parties including:
• Business partners, agents, suppliers and sub-contractors, for example our mailing house, software developers, registration partners or ABC
(www.abc.org.uk), for the performance of any contract for products or services which we enter into with you, or to allow you to participate in any
competition or prize draw which you have entered.
• Exhibitors, where you scan your badge at an exhibition stand, and sponsors of sponsored sessions at an event or conference.• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. (We do not however disclose
information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users to help them reach
the kind of audience they want to target.)
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.• Credit reference agencies for the purposes of assessing your credit score where this is a condition of us entering into a contract with you.
We may also disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such
business or assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms
and conditions and/or other agreements; or to protect our rights, property, or safety or the rights, property and safety of others. This includes
exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• We do not share your information with any direct mail organisations or other third parties unconnected with the provision of our activities.
Some of our external third parties are based outside the European Economic Area (EEA). This will involve transferring your 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:
• 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.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.
All information you provide to us is stored on our secure servers. We also use a secure payment provider, Square to process all electronic payment transactions. All credit card information is protected by Square and they use a trusted source Secure Sockets Layer (SSL) Software to encrypt electronic transactions.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at info@clinica-aesthetics.uk
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.
We will only retain your personal data for as long as necessary to fulfill 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.
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.
If you wish to exercise any of the rights set out above, please contact us.
Any changes we may make to this policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.
Contact
Questions, comments and requests regarding this privacy policy, or any requests to exercise your legal rights, should be sent to info@clinica-aesthetics.uk
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 opportunity to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Privacy Policy
• 1. Privacy Statement
• 2. Data Protection Regulations
• 3. What information do We collect from you?
• 4. Cookies
• 5. How do We use the information?
• 6. How do We handle your information?
• 7. To whom may We disclose your information?
• 8. How can I control use of my information?
• 9. Changes to Privacy Statement
• 10. Your right to complain
1 Privacy Statement
1.1 This Website is owned by Clinca Aesthetics.1.2 The Data Protection (Bailiwick of Guernsey) Law 2017, The Data Protection (Jersey) Law 2018 and the new European General Data Protection Regulation (implemented in the UK on 25 May 2018) (the “Regulations”) set out Our responsibilities. We have to protect your data.
1.3 This Privacy Statement sets out the way We will obtain and hold your Personal Data. This is known as “Processing”. When read together with Our Terms and Conditions of Use and Cookie Policy, this Privacy Statement covers Our relationship with you in relation to this Website. By continuing to browse and use this Website, you agree to this Privacy Statement. If you disagree with any part of this Privacy Statement, please do not use Our Website.
1.4 Any questions, comments and requests you may have regarding this Privacy Statement are welcomed and should be addressed to: Data Protection Officer, Clinica Aesthetics, info@clinica-aesthetics.uk
2 Data Protection Regulations
2.1 For the purposes of this Privacy Statement: (a) We determine the purposes for which and the manner in which your personal data is, or is to be processed, and we are known as the data controller (“Data Controller”); and (b) in submitting your data and information to us to collect, handle and process, you will be the individual who is the subject of the data (the “Data Subject”); and (c) in processing your data and information, any other parties contracted to process data by the Data Controller will be known as (“Data Processors”).3. What information do We collect from you?
3.1 We may collect and process the following data and information that you give us if you fill in the Account Registration Form, place an order for Goods, or if you submit content on Our Website or otherwise by corresponding with us by phone email or otherwise: (a) name and date of birth; (b) contact information including address, email address, phone number; (c) information necessary for the purposes of submitting an order for prescription products application; (d) prescribed medication and directions for use.3.2 We understand that the data collected at 3.1(c) and 3.1(d) is Sensitive Personal Data.
3.3 We will collect and process the following data automatically from your visit to Our Website: (a) technical information, including the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; (b) information about your visit, including the full uniform resource locator (URL), clickstream to, through and from Our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call Our customer service number and any other anonymised data or metrics that identify user behaviour and the habits of web visitors.
4.1 By visiting this website, you consent to its use of cookies to distinguish you from other users. The use of cookies in no way gives Us access to your computer or any Personal Data, other than the data and information you choose to share with Us.
4.2 You may choose to accept or decline cookies by modifying your own browser’s settings.
4.3 Further information of the cookies We use and how they work is available in Our Cookie Policy.
5.1 We shall use the data and information you give to Us: (a) to allow you to create an account and on the Website; (b) to process and analyse your order(s) including dispensing and dispatching the products; (c) to keep and maintain Our internal business records; (d) for our internal training purposes; (e) if you give us express consent, to provide you with Our own tailored marketing information that We think may suit your interests and needs.
5.2 We reserve the right to add to the list of uses in clause 5.1. We shall not use pre-collected data and information for any new uses of your data without consulting you and obtaining your express consent if we are required to do so under the Regulations.
5.3 Where you provide us with information for the purposes of account registration and orders described above, We may use such information provided in order to verify the information provided, process your application and order. We may also transfer the data to our Data Processors in order to fulfil or analyse your order.
5.4 We reserve the right to anonymise your data to obtain analysis while retaining your privacy.
6.1 The data and information We collect from you will be transferred to and securely stored by our hosting third party: Ionos 1 and 1.
6.2 We are committed to ensuring that your data and information is secure. In order to prevent unauthorised access or disclosure, We have put in place suitable physical, electronic and Office procedures to safeguard and secure the information We collect online, including: (a) all data and information you provide to us is stored on secure servers; (b) any payment transactions will be encrypted Using SSL technology; (c) where We have given you (or where you have chosen) a password which enables you to access certain parts of Our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone; (d) erasing of information, and destruction of any copies kept; (e) regularly updating our review procedure.
6.3 Any Sensitive Personal Data that we collect as described at clause 3.1(c) and 3.1(d) shall be processed in accordance with the Regulations, and only to permit Us to process your request or enquiry. Your Sensitive Personal Data will be stored securely and will not be passed on to third parties.
7.1 In providing us with data and information, you agree that We may disclose such information, where necessary for the purposes and uses listed in clause 5, to: (a) Our employees, agents representatives and any Data Processors officially contracted to process the data on Our behalf; (b) selected third parties including: (i) business partners, suppliers and sub-contractors for the performance of any contract We enter into with you; (ii) analytic and search engine providers that assist us in the improvement and optimisation of Our Website; (c) any other third parties We are legally obliged to disclose your information to.
7.2 We will only disclose your Personal Data to parties who bear sufficient legal responsibility for its protection and who have sufficient privacy and security measures in place to reasonably ensure that it will be protected and handled appropriately.
7.3 We may disclose your Personal Data to third parties: (a) in the event that We sell or buy any business or assets, in which case We will disclose your Personal Data to the prospective seller or buyer of such business or assets; (b) if Our assets, or substantially all of Our assets are acquired by any third parties, in which case personal data held by it about Our customers will be one of the transferred assets; (c) if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply Our terms of use; or to protect Our rights, property or safety of Our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
8.1 You may choose to restrict the collection or use of your Personal Data in the following ways: (a) by leaving the “third party opt-in” box EMPTY on the Account Registration Form. If you do not consent we shall assume that you do not want the data and information to be used by us or by third parties for analytical, marketing and promotional purposes; (b) if you have previously agreed to us using your Personal Data for direct marketing purposes, you may change your mind at any time by emailing us at info@clinica-aesthetics.uk .
8.2 The Regulations gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request will be free. If you would like a copy of the information held on you please email us at Data Protection Officer, Clinica Aesthetics, info@clinica-aesthetics.uk
8.3 If you believe that any information We are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.
9.1 We reserve the right to make changes to this policy without notice from time to time by updating this page. Every time you wish to use Our Website, please check the statement to ensure you understand the terms that apply at that time. 9.2 The current statement was made effective as of May 2018 and incorporates the requirements of the new GDPR which came into effect on 25th May 2018.
10.1 If you believe that your information held by us is not being handled properly, you have the right to complain to the Data Commissioner.
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