This Application collects some Personal Data from its Users.
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Images Face & Body Studio Ltd
39 King St, Bathgate EH48 1AZ
Owner contact email: email@example.com
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies; Usage Data; first name; last name; phone number; email address.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
The Owner may process Personal Data relating to Users if one of the following applies:
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Interaction with external social networks and platforms and Contacting the User.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Personal Data is collected for the following purposes and using the following services:
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: email address; first name; last name; phone number.
This type of service allows interaction with social networks or other external platforms directly from the pages of this Application.
The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on this Application isn’t being connected back to the User’s profile.
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data processed: Cookies; Usage Data.
The following privacy notice outlines how Images Face & Body Studio Ltd collects, uses, protects
and transfers your personal data.
The data protection officer/data owner for the organisation is Karen Begg. You can contact the data
protection officer/data owner by sending an email to Karen Begg - firstname.lastname@example.org
or writing to 39 King Street, Bathgate EH48 1AZ.
Personal data collected
The personal data that we collect is:
· Home address
· Email Address
· Date of Birth
· Phone number
· Health information
Purpose and Legal Basis for Processing your Data
Images Face & Body Studio Ltd 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
We need to obtain and process your personal data to provide you with our products,
services and treatments 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.
Who is processing my data?
Images Face & Body Studio Ltd, 39 King St, Bathgate EH48 1AZ are the data controller and processes
your personal information for the purposes laid out in this privacy notice. Phorest, Anglesea Mills, 9
Anglesea Row, Smithfield, Dublin 7, D07 W5NE, Ireland, acts as data processor on behalf of Images
Face & Body Studio Ltd and have access to personal information only [GG1] in cases that customer
support or troubleshooting is required by Images Face & Body Studio Ltd. Further, they must
process the personal information in accordance with this Privacy Notice and as permitted by
applicable data protection laws.
Your personal data is processed to:
· Collect specific personal data (name, address, email, contact number, DOB) that is required to
enter into a contract to sell a product or service.
· 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.
Your rights as the individual
If your personal data is held by Images Face & Body Studio Ltd 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 Images Face & Body Studio Ltd
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 personal data and to 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 r estrict processing , to ‘block’ processing of your personal data.
· T o data portability, having your data moved, copied or transferred from
[Organisation] to another organisation in an easily readable format.
· To object to direct marketing from us.
Special categories of personal data
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. Images Face & Body Studio Ltd asks 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 we
only use this information 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, in Images Face & Body Studio Ltd salons, by email, social media, in
writing or any other means by which you provide it to us. Information is stored using
the Phorest software platform as well as some level of paper record keeping.
Images Face & Body Studio Ltd gives you access to information about your [GG2] account and
bookings through Phorest software, for the limited purpose of viewing and updating
Images Face & Body Studio Ltd does not collect the personal data of children under the age of 16
without [GG3] parental or guardian consent. If you believe that we hold any
information from or about a child under age 16, please contact Images Face & Body Studio Ltd
and if we cannot immediately obtain appropriate parental or guardian consent, will
remove the personal data from storage.
Data [GG4] Sharing
Your personal data is shared only with Phorest representatives in cases that
customer support and troubleshooting is required for the salon. Images Face & Body Studio Ltd
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 [GG5]
Data processors are third parties who provide some elements of our business
services for us. Where we use a third-party, we 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 we work will never share or
disclose your personal information and will hold it securely at all times.
Images Face & Body Studio Ltd use software provided by Phorest to [GG6] [insert why it is used,
what data it holds etc].
Here is a link to their Privacy Notice.
How Long Do We Keep Your Data?
Images Face & Body Studio Ltdretains your personal data for as long as necessary to provide you
with our services as our client. Images Face & Body Studio Ltdare 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
· 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
Transfers of personal information
When your personal data is processed through 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. During this process your data is encrypted in transit
and at rest.
Consequences of not providing your
personal information to Images Face & Body Studio Ltd
In the event that you want to purchase a product or service from [organisation],
certain personal information is required to enter into a contract with you.
[organisation] 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. Your 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 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 and can only access
the salon software with the PIN number assigned to them by the management of the
In the occurrence that you want to make a complaint about how your personal data
was gathered, how it is being processed by Images Face & Body Studio Ltd(or third parties used
by Images Face & Body Studio Ltd or you are not satisfied about how a complaint has been
handled, you retain the right to lodge a complaint directly with the supervisory
authority and Images Face & Body Studio Ltd and also the Images Face & Body Studio Ltd Data Protection
Officer/ GDPR Owner.
Data Protection Supervisory Authority
Data Protection Commissioner, Canal House, Station Road, Portarlington, Co. Laois,
Ireland [GG7] R32 AP23
+353 (0) 57 8684800
Data Protection Commissioner, Information Commissioner's Office, Wycliffe House,
Water Lane, Wilmslow, Cheshire [GG8] , SK9 5AF
+44 (0) 303 123 1113
Images Face & Body Studio Ltd Data Protection Officer/GDPR Owner
[GG1] Any other reasons to access the data ?
[GG2] Please comment on what the salon clients can do with their account
[GG3] Age 13 needs to go in for salons in England.
Age in Ireland 16 at the moment but it has been recommended that it changes to 13 and this
could happen before May 25 th 2018
[GG4] I have not included the sharing of anonymised data here as data that is completely
anonymised and the individual can no longer be identified because or through that data, is
no longer classed as personal data and so is not under the remit of the GDPR.
[GG5] The salon needs to include other data processors that they use here. Example payroll
[GG6] Explain why the salon uses Phorest’s software.
[GG7] Use this address if the salon is in Ireland.
[GG8] Use this address on the form if the salon is in England.
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
The means by which the Personal Data of the User is collected and processed.
The service provided by this Application as described in the relative terms (if available) and on this site/application.
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User's device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).