IN YOUR OWN SKIN
London W1G 8QS
020 7436 3936
The Face and Body Clinic
This Policy describes the information that The Face and the Body Clinic (“we” or “us”) gathers on or through the Service, how we use and disclose such information, and the steps we take to protect such information. By visiting the Site, or by purchasing or using any Services, you consent to the privacy practices described in this Policy.
“Client” means a customer of ours.
“Client Data“ means personal data, reports, addresses, and other files, folders or documents in electronic form that a User of any of our Services stores within the Service which would include but not be limited to [ uploaded by a Client to our Site].
“Personal Data” means information that specifically identifies an individual or that is linked to information that identifies a specific individual.
“Public Area” means the area of the Site that can be accessed both by Users and Visitors, without needing to use a login ID and a password.
“Restricted Area” means the area of the Site that can be accessed only by Users, and where access requires the use of a login ID and a password.
“User” means a Client or an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.
“Visitor” means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or Service.
The Information We Collect on the Service:
We collect different types of information from or through the Service:
User-provided Information. When you use the Service, as a User or as a Visitor, you may provide, and we may collect Personal Data. Examples of Personal Data include name, email address, mailing address, mobile phone number, and credit card or other billing information. Personal Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Personal Data in various ways on the Service. For example, when you register for an Account, use the Service, post Client Data, interact with other users of the Service through communication or messaging capabilities, or send us customer service -related requests.
Information Collected by Clients. A Client or User may store or upload into the Service Client Data. Each Client is responsible for providing notice to third persons concerning the purpose for which the Client collects their Personal Data and how this Personal Data is processed in or through the Service as part of Client Data.
“Automatically Collected" Information. When a User or Visitor uses the Service, we may automatically record certain information from the User’s or Visitor’s device by using various types of technology, including cookies, “clear gifs" or “web beacons.” This “automatically collected" information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Service, the pages or other content the User or Visitor views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding a Visitor or User’s interaction with email messages, such as whether the Visitor or User opens, clicks on, or forwards a message. This information is gathered from all Users and Visitors.
Information from Other Sources.
We may obtain information, including Personal Data, from third parties and sources other than the Service, such as [our partners, advertisers, credit rating agencies, and Integrated Services]. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.
How We Use the Information We Collect
We use the information that we collect in a variety of ways in providing the Service and operating our business, including the following:
We use the information – other than Client Data - to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process Client Data solely in accordance with the directions provided by the applicable Client or User.
We use the information – other than Client Data - to understand and analyze the usage trends and preferences of our Visitors and Users, to improve the Service, and to develop new products, services, features, and functionality.
We may use a Visitor’s or User’s email address or other information – other than Client Data – to contact that Visitor or User (i) for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or other issues related to the Client Data or Personal Data posted on the Service or (ii) with updates on promotions and events, relating to services offered by us and by third parties we may work with. You have the ability to opt-out of receiving any promotional communications as described below under “Your Choices.”
Cookies and Tracking Technologies
“Cookies” are text-only pieces of information that a website transfers to an individual’s hard drive or other website-browsing equipment for record-keeping purposes. Cookies allow the Site to remember important information that will make your use of the Site more convenient.
To Whom We Disclose Information
Except as described in this Policy, we will not intentionally disclose the Personal Data or Client Data that we collect or store on the Service to third parties without the consent of the applicable Visitor, User or Client. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
Any information that you voluntarily choose to include in a Public Area of the Service, such as [on a chat forum] [or a banner advertisement], will be available to any Visitor or User who has access to that content.
[We work with third party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information]
Non Personally Identifiable Information
We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Clients’, Users’ and Visitors’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service.
Law Enforcement, Legal Process and Compliance
We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
Transfer of Ownership
Access, Correction, Deletion
We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete any information about you that we have obtained from an Integrated Service, you may contact us as set forth in the “Contact Us” section. At your request, we will have any reference to you deleted or blocked in our database.
You may update, correct, or delete your Account and or Account information and preferences at any time by [accessing your Account settings page on the Service] contacting us at firstname.lastname@example.org
Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service.
At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law.
This provision does not apply to Personal Data that is part of Client Data. In this case, the
You may opt out from the collection of navigation information about your visit to the Site by [Google Analytics by using the Google Analytics Opt-out feature.
Opting out from Commercial Communications
If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided above or in the [“Contact Us” section].
Users are able to view and modify settings relating to the nature and frequency of promotional communications that they receive from us by [contacting us using the unsubscribe option link contained within the email].
Please be aware that if you opt-out of receiving commercial emails from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to [ten (10)] business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.
If a Client requests us to remove any data, we will respond to its request within [fifteen (15) days. We will delete, amend or block access to any Personal Data that we are storing only if we receive a written request to do so from the Client who is responsible for such Personal Data, unless we have a legal right to retain such Personal Data. We reserve the right to retain a copy of such data for archiving purposes, or to defend our rights in litigation. Any such request regarding Client Data should be addressed as indicated in the [“Contact Us”] section, and include sufficient information for us to identify the Client and the information to delete or amend.
The Services we provide may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information].
Your Privacy Rights
We will not share any Personal Data with third-parties for their direct marketing purposes to the extent prohibited by law. If our practices change, we will do so in accordance with applicable laws and will notify you in advance.
Interest Based Advertising
Interest based advertising is the collection of data from different sources and across different platforms in order to predict an individual’s preferences or interest and to deliver to that individual, or his/her computer, smart phone or tablet, advertising based on his/her assumed preference or interest inferred from the collection of data pertaining to that individual or others who may have a similar profile or similar interests.
[We work with a variety of third parties to attempt to understand the profiles of the individuals who are most likely to be interested in our Services so that we can send them promotional emails, or serve our advertisements to them on the websites and mobile apps of other entities.
These third parties include: (a) advertising networks, which collect information about a person’s interests when that person views or interacts with one of their advertisements; (b) attribution partners, which measure the effectiveness of certain advertisements; and (c) business partners [or insert as appropriate], which collect information when a person views or interacts with one of their advertisements.
In collaboration with these third parties, we may collect information about our customers, prospects and other individuals over time and across different platforms when they use these platforms or interact with them. [Individuals may submit information directly on our Sites or on platforms run by third parties, or by interacting with us, our advertisements, or emails they receive from us or from third parties. We may use special tools that are commonly used for this purpose, such as cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar technologies. We may have access to databases of information collected by our business partners].
The information we or third party collect enables us to learn what purchases the person made, what ads or content the person sees, on which ads or links the person clicks, and other actions that the person takes on our Sites, or in response to our emails, or when visiting or using third parties’ platforms.
We, or the third parties with which we work, use the information collected as described above to understand the various activities and behaviors of our customers, Site visitors and others. We, or these third parties, do this for many reasons, including: to recognise new or past visitors to our Sites; to present more personalised content; to provide more useful and relevant ads - for example, if we know what ads you are shown we can try not to show you the same ones repeatedly; to identify visitors across devices, third party websites and sites, or to display or send personalized or targeted ads and other custom content that is more focused on a person’s perceived interest in products or services similar to those that we offer.
Our interest-based ads may be served to you in emails or on third-party platforms. We may serve these ads about our products or services or send commercial communications directly ourselves or through these third parties.
Visitors may opt out of receiving interest based advertising by advertising networks that may be delivered to them on our platform and other websites by visiting the following website: www.thefaceandbodyclinic.co.uk
These features will opt a Visitor out of many – but not all - of the interest-based advertising activities in which we or third parties engage.]
Third Party Cookies
We are legally required to disclose whether other third parties may collect personally identifiable information about an individual's online activities from our Site or Service.
The information gathered by these third parties is used to make predictions about your interests or preferences so that they can display advertisements or promotional material on this Site and on other sites across the Internet tailored to your apparent interests.
The business partners and advertising networks that serve interest-based advertisements on the Services have limited access to a small amount of information about your profile and your device, which is necessary to serve you advertisements that are tailored to your apparent interests. It is possible that they may reuse this small amount of information on other sites or services.
Protecting the privacy of minors is especially important. Our Service is not directed to minors under the age of 18, and we do not knowingly collect Personal Data from persons under the age of 18 without obtaining parental consent.
If you are under 18 years of age, then please do not use or access the Service at any time or in any manner.
Please be aware that, although we offer this deletion capability, the removal of content may not ensure complete or comprehensive removal of that content or information.
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We use ISO certified cloud services and applications. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorised alteration, unauthorised disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use TLS technology to encrypt data during transmission through public internet and ISO certified cloud services and applications, [and we also employ application-layer security features to further anonymise Personal Data.]
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the [“Contact Us”] section.
If we learn of a security systems breach, we will inform you of the occurrence of the breach in accordance with applicable law.
We only retain the Personal Data collected from a User for as long as the User’s account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will only retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Although we may allow you to adjust your privacy settings to limit access to certain Personal Data, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Service. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorised persons.
[The Company will not transfer personal information outside the European Economic Area (EEA), which comprises the countries in the European Union and Iceland, Liechtenstein and Norway.
The Company may transfer personal information outside the European Economic Area (EEA)
(which comprises the countries in the European Union and Iceland, Liechtenstein and Norway) on the basis [that that country, territory or organisation is designated as having an adequate level of protection OR that the organisation receiving the information has provided adequate safeguards by way of [binding corporate rules OR standard data protection clauses OR of compliance with an approved code of conduct.]
The Company will ensure that staff are adequately trained regarding their data protection responsibilities. Individuals whose roles require regular access to personal information, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them.
The Service is hosted in the UK. If you choose to use the Service from regions of the world with laws governing data collection and use that may differ from EU and UK law, then please note that you are transferring your Client Data and Personal Data outside of those regions to the UK for storage and processing. Also, we may transfer your data to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Service. By providing any information, including Client Data and Personal Data, on or to the Service, you consent to such transfer, storage, and processing.
Data Controller and Data Processor
We do not own, control or direct the use of any of the Client Data stored or processed by a Client or
User via the Service. Only the Client or Users are entitled to access, retrieve and direct the use of such Client Data. We are largely unaware of what Client Data is actually being stored or made available by a Client or User to the Service and do not directly access such Client Data except as authorised by the Client, or as necessary to provide Services to the Client and its Users.
Because we do not collect or determine the use of any Personal Data contained in the Client Data and because it does not determine the purposes for which such Personal Data is collected, the means of collecting such Personal Data, or the uses of such Personal Data, we are not acting in the capacity of data controller in terms of the European Union’s Directive 95/46/EC on data privacy or the European Data Protection Regulation (“GDPR”) and do not have the associated responsibilities under GDPR.
The Client or the User is the data controller under the Directive for any Client Data containing Personal Data, meaning that such party controls the manner such Personal Data is collected and used as well as the determination of the purposes and means of the processing of such Personal Data.
We are not responsible for the content of the Personal Data contained in the Client Data or other information stored on our servers (or our subcontractors’ servers) at the discretion of the Client or User nor are we responsible for the manner in which the Client or User collects, handles disclosure, distributes or otherwise processes such information.
Changes and Updates to this Policy
Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service
after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.
How to Contact Us
Please contact us with any questions or comments about this Policy, your Personal Data, our use and disclosure practices, or your consent choices by email at email@example.com
Or via our website “Contact Us section”.
GDPR Special mention_ on your Individual Rights updated on 18th May 2018
We have added this section so you are fully aware of your rights and how to exercise your rights
Individual Rights (Data Privacy) Policy
1.1 UK data protection law gives individuals whose personal information is collected and/or used rights in respect of such information.
1.2 Any individual (including an employee, contractor, director, investor or financial professional) whose personal information is collected will benefit from these rights in accordance with the provisions of this Data Protection Rights Policy (Policy).
2.1 To ensure that we handle personal information in accordance with the law.
2.2 To explain how we deal with a request from an individual to exercise their data protection rights.
3. Individual's Data Protection Rights
3.1 We must assist individuals to exercise the following data protection rights, consistent with the requirements of applicable UK data protection law:
3.1.1 The right of access: This is a right for an individual to obtain confirmation whether a controller processes personal information about them and, if so, to be provided with details of that personal information and access to it. The process for handling this type of request is described further in sections 3 and 4 below;
3.1.2 The right of rectification: This is a right for an individual to obtain rectification without undue delay of inaccurate personal data a controller may process about them;
3.1.3 The right to erasure: This is a right for an individual to require a controller to erase personal information about them on certain grounds – for example, where the personal information is no longer necessary to fulfil the purposes for which it was collected;
3.1.4 The right to restriction: This is a right for an individual to require a controller to restrict processing of personal information about them on certain grounds;
3.1.5 The right to object: This is a right for an individual to object, on grounds relating
to their particular situation, to a controller's processing of personal data about them, if certain grounds apply;
3.1.6 The right to data portability: This is a right for an individual to receive personal information concerning them from a controller in a structured, commonly used and machine-readable format and to transmit that information to another controller, if certain grounds apply.
3.2 If any Request is received in relation to a data subject’s rights (including the right to
rectification, erasure, restriction, object or data portability) the Request must be referred to THE FACE AND BODY CLINIC Team at firstname.lastname@example.org
4. Right of Access
4.1 An individual making a valid Request is entitled to:
4.1.1 Be informed whether we hold and are processing personal information about them;
4.1.2 Be given a description of the personal information, the purposes for which they
are being held and processed and the recipients or classes of recipient to whom the personal information is, or may be, disclosed by tus; and
4.1.3 Communication of their personal information held by us in a form that is understandable, without compromising the privacy of other individuals.
4.2 The Request must be made in writing, which can include email.
5. From 25 May 2018, we must provide information on action taken on a Request within one month of receipt of the Request. That period may be extended by two further months where necessary, taking into account the complexity and number of the Requests
5.1 An individual may make a Request only in respect of their own personal information. With that said, an individual may give their consent, in writing, to another individual to make a Request on their behalf (e.g. a lawyer acting on behalf of the individual).
5.2 In some cases personal information may be withheld if an exemption applies. Decisions about the appropriate use of exemptions should always be made by the FOIA Team.
6.1 Receipt of a Subject Access Request
6.2 If an individual makes a Request for their personal information, the Request must be passed to THE FACE AND BODY CLINIC Team at email@example.com
6.3 The date on which the Request was received together with any other relevant information should be recorded.
6.4 Initial steps
6.4.1 THE FACE AND BODY CLINIC Team will make an initial assessment of the Request to decide whether it is valid and whether confirmation of identity, or any further information, is required.
6.4.2 THE FACE AND BODY CLINIC Team will then contact the individual in writing to confirm receipt of the Request and seek confirmation of identity or further information.
6.5 Exemptions to subject access
6.5.1 A valid request may be refused in accordance with the relevant exemptions set out in UK data protection law and regulatory guidance, including;
(a) Impossibility or burden of providing access
• A right to access may be restricted where providing access would be impossible or involve disproportionate effort.
• When contemplating whether to withhold information due to such reasons, we must consider many factors, such as whether the personal information is used for decisions that significantly affect the individual. Expense and burden are important factors and should be taken into account, but they are not definitive in determining whether providing access is reasonable.
(b) Confidential commercial information
• We may also deny or limit access to personal information to the extent that granting full access would reveal confidential commercial information (e.g. where the information is subject to contractual obligations of confidence or is being processed as part of an ongoing audit, investigation or enforcement activities).
(c) Public interest exemptions
• We are not obliged to provide information where a public interest exemption applies. Such exemptions may include where disclosure of the information may interfere with important public interests, such as national security, defence or public security. Other reasons for denying or limiting access are:
(i) Interference with the execution or enforcement of the law or with private causes of action;
(ii) Where the legitimate rights or important interests of others would be violated;
(iii) Breaching a legal or other professional privilege or obligation;
(iv) Prejudicing employee security investigations or grievance procedures or in connection with succession planning and corporate reorganizations;
6.5.2 Given our role as a regulator with enforcement and disciplinary functions, THE FACE AND BODY CLINIC Team shall give particular consideration to the application of exemptions (iii) to any Request.
6.5.3 Decisions about the use of exemptions should only ever be made by THE FACE AND BODY CLINIC Team. THE FACE AND BODY CLINIC Team will assess each request individually to determine whether any of the above-mentioned exemptions may apply and/or whether it can redact information and disclose the remaining personal information.
6.6 Appropriate methods for locating and disclosing personal information
6.6.1 THE FACE AND BODY CLINIC Team will arrange a search of all relevant electronic and structured paper filing systems.
6.6.2 Particular care must be taken where the Request concerns information whose disclosure would reveal personal information about other individuals. THE FACE AND BODY CLINIC Team has a responsibility to protect all personal information it processes and must not disclose other individuals' personal information in response to a Request if doing so is contrary to applicable privacy law or the lawful rights and freedoms of those individuals.
6.6.3 The personal information requested will be collated by THE FACE AND BODY CLINIC Team, with the assistance of other departments as appropriate, into a readily understandable format (e.g. internal codes or identification numbers used at THE FACE AND BODY CLINIC Team that correspond to personal information should be explained if applied). A letter will be prepared by THE FACE AND BODY CLINIC Team which includes information required to be provided in response to the Request.
6.6.4 Where the provision of the personal information in permanent form is not
possible or would involve disproportionate effort, there may be no obligation to provide a permanent copy of the requested information. In such circumstances the individual may be offered the opportunity to have access to the information by inspection or to receive the information in another form.
The other information referred to in 2.1 above must still be provided (unless an exemption under law applies).
6.7 Requests for erasure, amendment or cessation of processing of information
6.7.1 If a Request is received for the deletion or correction or any other right relating to an individual’s personal information, the Request must be referred to the THE FACE AND BODY CLINIC Team for advice.
6.8 All queries relating to this Policy are to be addressed to THE FACE AND BODY CLINIC Team at firstname.lastname@example.org