Privacy Policy
This privacy notice explains how we, Waxology, look after the personal information you give us or that we learn by having you as a client and the choices you make about marketing communications that you agree we may send you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.
TOPICS:
- What information we collect about you
- How information about you will be used
- Marketing
- Employment
- How long your information will be kept for
- Where your information is kept
- Access to your information and correction
- Cookies
- Other websites
- Changes to our privacy notice
- How to contact us
WHAT INFORMATION WE COLLECT ABOUT YOU
We collect information about you when you book an appointment for a service or treatment, visit the salon for a service or treatment, buy a product or apply for a job, whether contact is online, on paper, by email, over the phone or in person. The information you give us may include your name, address, email address, phone number, relevant history which may suggest that a service or treatment should not go ahead or certain products should not be used (e.g. allergies, pregnancy, skin conditions), payment and transaction information and CVs. We operate CCTV across the Newcastle premises for the safety and security of our clients and staff as well as a deterrent for the purpose of criminal activity. For clients under the age of 16, we will only keep and use their personal information with the consent of a parent, carer or guardian.
WHO IS PROCESSING MY DATA?
Waxology is the data controller and processes your personal information for the purposes as set out in this privacy notice. Waxology also use third party operators to provide some business services. Ovatu Pty Ltd and Best Business Services Ltd act as data processors on behalf of the salon and have access to personal information only in cases that customer support or troubleshooting is required by Waxology. Furthermore, they must process the personal information in accordance with this Privacy Notice and as permitted by applicable data protection laws.
Ovatu’s full privacy policy can be found here https://ovatu.com/uk/privacy
Ovatu also use a third party to process booking payments – Stripe Payments Europe, Ltd. When you make payments or conduct transactions through Ovatu, Stripe receive your transaction information. The information that Stripe collects will include payment method information (such as credit or debit card number, or bank account information), purchase amount, date of purchase, and payment method. Different payment methods may require the collection of different categories of information. Stripe’s full privacy policy can be found here https://stripe.com/gb/privacy
HOW INFORMATION ABOUT YOU WILL BE USED
Waxology takes your privacy seriously and we will never sell or rent your personal data to any third-party. Sharing of your data and direct marketing activities are only carried out with your express consent, which you are free to withdraw at any time.
In law, we are allowed to use personal information, including sharing it outside the salon, only if we have a proper reason to do so, for example:
- To fulfil a contract with you i.e. to provide the service or treatment you have requested and to communicate with you about your appointments
- When it is in our legitimate interest i.e. there is a business or commercial reason to do so, unless this is outweighed by your rights or interests
- When you consent to it: we will always ask for your consent to hold and use health and medical information.
- Engage in communication with you including confirmation and reminders of appointments, and requests to cancel or change bookings.
- Collect health information to perform the agreed services appropriately, and potentially highlight areas that products and services may cause issues to clients because of their health.
- Ensure a safe service and provide industry standard advice.
- Select relevant offers, promotions and information for you.
- Estimate the number of customers we have.
- Hold personal data that is required by law or to respond to legal process.
- Hold for insurance purposes.
- Store customer records.
We will therefore share your information with:
Providers of our salon IT system: Ovatu Pty Ltd ABN 92 159 394 484 – to manage the salon appointment scheduling, payment processing, CRM and marketing.
Providers of our payment processing system via Ovatu: Stripe Payments Europe Ltd – to take payments for treatment bookings.
Providers of our Phone Answering Service: Best Business Services Ltd – to answer phone calls and book appointments in to the Ovatu system.
All of our suppliers have rigorous data protection and security policies in place.
We will not share your information with any other third party without your consent except to help prevent fraud, or if required to do so by law.
MARKETING
We would like to send you information about products and services, which may be of interest to you. We will ask for your consent to receive marketing information.
If you have consented to receiving marketing, you may opt out at a later date.
You have the right at any time to stop us from contacting you for marketing purposes or giving your information to third party suppliers of products or services. If you no longer wish to be contacted for marketing purposes, please contact us.
EMPLOYMENT
The information we collect about employees, the purposes it is used for and those who it will be shared with is set out in our employment contracts and employee handbook.
HOW LONG YOUR INFORMATION WILL BE KEPT FOR
Unless you request otherwise, we will keep your information to contact you no more than 12 times per year for a maximum of 1 year from your last visit to the salon.
After a year we will archive all your personal information, except for your name, relevant client history (e.g. allergy test records which we keep for 4 years) and financial transactions (which we are obliged to keep for 6 years).
Information about unsuccessful job applicants will be deleted after four months.
CCTV images are automatically deleted after 30 days.
WHERE YOUR INFORMATION IS KEPT
Your personal information data is encrypted, stored, and backed up securely by Ovatu on servers in the United States, which complies with GDPR via the US/EU Security Shield framework. No sensitive card details are stored by Ovatu.
Any payment transactions are encrypted and stored by Stripe (who have Level 1 PCI Certification). Sending information via the internet is not completely secure, although we will do our best to protect your information and prevent unauthorised access.
ACCESS TO YOUR INFORMATION AND CORRECTION
You have the right to request a copy of the personal information that we hold about you. This will normally be free, unless we consider the request to be unfounded or excessive, in which case we may charge a fee to cover our administration costs.
If you would like a copy of some or all of your personal
information, please contact Frances Dobby, the Data Protection Officer, by
emailing info@waxologywaxing.co.uk
We want to make sure that your personal information is accurate and up-to-date. You may ask us to correct or remove information you think is inaccurate.
You have the right to ask us to object to our use of your personal information, or to ask us to delete, remove or stop using your personal information if there is no need for us to keep it.
Special categories of personal data collected
Health questions are asked in many of our 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. Waxology asks for consent to gather and process 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 we only use this information for determining your suitability for the treatment.
E-NEWSLETTERS
We email e-newsletters to inform you about products, services and treatments provided by our salon. You have the opportunity to unsubscribe from e-newsletters at any time.
E-newsletters may contain subscriber tracking facilities within the actual email, for example, whether emails were opened or forwarded, which links were clicked on within the email content, the times, dates and frequency of activity. We use this information to refine future email campaigns and provide you with more relevant content based around your activity.
COOKIES
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This is used to track visitor use of the website and to compile statistical reports on website activity. For further information visit www.aboutcookies.org or www.allaboutcookies.org
Our site does not use Cookies.
OTHER WEBSITES
Our website includes links to other websites. This privacy notice only applies to this website so when you link to other websites you should read their own privacy notices.
CHANGES TO OUR PRIVACY NOTICE
We keep our privacy notice under regular review and we will place any updates on this webpage or on the printed copy. This privacy notice was last updated on 22nd January 2019.
HOW TO CONTACT US
Please contact us if you have any questions about our privacy notice or information we hold about you:
- By email info@waxologywaxing.co.uk
You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern:
YOUR RIGHTS AS THE INDIVIDUAL
If your personal data is held by Waxology, 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 Waxology Data 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 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 Waxology to another organisation in an easily readable format.
· To object to direct marketing from us.
Consequences of not providing your personal information to Waxology.
In the event that you want to purchase a product or service from Waxology, certain personal information is required to enter into a contract with you. Waxology 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.
DATA RETENTION POLICY
This policy sets out what information Waxology holds, how long we hold it for and when it will be deleted.
It also covers the procedure to follow regarding data requests.
- Information held by us
- How long is personal data held for?
- Where is personal data held?
- How is personal data deleted?
- Access to personal information, correction and deletion
INFORMATION HELD BY US
We hold personal information about:
- Clients
- Former clients and prospective clients
- Employees
- Job applicants
We also hold information about financial transactions relating to these e.g. services or treatments provided, products bought, payroll information.
HOW LONG IS PERSONAL DATA HELD FOR?
We aim not to hold personal data longer than necessary.
Unless requested by an individual, the following types of data will be held for the periods shown below, after which it will be securely deleted or destroyed:
TYPE OF INFORMATION
RETENTION PERIOD
Client general records
6 years – however they are archived after 12 months of non activity
Client health records
4 years
Financial transactions, invoices and supplier details
6 years
Employee records, contracts of employment, changes to terms and conditions, annual leave, training records
While employment continues and up to 6 years after employment ends
Payroll and wage records including PAYE, income tax, national insurance, sick pay, redundancy payments
6 years from the financial year-end in which payments were made
Maternity records
3 years after the end of the tax year in which the maternity pay period ends
Job applications (unsuccessful)
4 months after notifying unsuccessful candidates
Emails
One year from the end of the month in which they were received or sent unless a longer period is relevant as above. Emails to and from ex-employees or contractors will be deleted within 2 weeks of them leaving unless these form part of the employment record – see above.
WHERE IS PERSONAL DATA HELD?
See “Privacy Policy” for details
Safeguarding your Personal Data
Appropriate measures are taken to protect your personal data from access by unauthorised persons or inappropriate access, internally or externally.
Employees and our third party agents are assigned specific access rights and can only access the salon software with the PIN number assigned to them by the management of the salon.
Connections to the Ovatu system are encrypted to ensure the safeguarding and security of your data.
We do not hold paper records.
HOW IS PERSONAL DATA DELETED?
Personal data is permanently deleted in accordance with the retention periods listed above from:
- Salon software system – Ovatu
- Emails
ACCESS TO PERSONAL INFORMATION, CORRECTION AND DELETION
See our privacy notice
All requests for access to personal information will be handled by Frances Dobby, the Data Protection Officer.
Responses to requests will be made within 30 days.
All information relating to the individual will be compiled into a report and collected from:
- Salon software system
- Financial transactions
- Emails
- Other electronic records
- Paper records (where applicable)
