Privacy Policy

We appreciate your interest in our Privacy Policy. This Privacy Policy applies to www.flawlessaesthetics.org.uk (our “website”).We would like to ask you to read this policy along with our Cookie Policy.

General Information 

What law applies?

In principle, we will only use your personal data in accordance with the applicable data protection laws, in particular the UK`s Data Protection Act (“DPA”) and the EU counterpart the General Data Protection Regulation (“GDPR”).

Who is responsible for data processing?

The responsible party within the meaning of the DPA and the GDPR is Flawless Aesthetics, Cushat Gardens, Mayfield, EH225RQ, United Kingdom (“Flawless Aesthetics”, “we”, “us”, or “our”). If you have any questions or if you wish to exercise your rights, please contact us using [email protected], call us on 07498257736, or write to us at the above address.

What is Personal Data?

Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data. This includes, for example, the number of users of a website. 

What is Special Category Data?

Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to explicitly consent to the processing.

What is processing?

“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

What are the legal bases of processing?

In accordance with the DPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data:

• you have given your consent,
• the data is necessary for the fulfilment of a contract / pre-contractual measures,
• the data is necessary for the fulfilment of a legal obligation, or
• the data is necessary to protect our legitimate interests, provided that your interests are not overridden. 

Data we collect automatically

Log data

Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user’s device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.

Content Delivery Network

We use a Content Delivery Network (CDN) to distribute our online content. Our CDN is a network of regionally distributed servers of our technical service providers connected via the Internet. When our website is visited, your device`s browser transmits information to these service providers, which is collected in corresponding server log files. Server log files are generally anonymised and then transmitted without any personal reference. Server log files include, in particular, i) details of the browser and operating system used, ii) the previously visited pages (so-called referral URL), iii) the IP address of the device used, iv) the name of the Internet provider, as well as v) the date, time of all page views including the amount of data transmitted. The legal basis for processing is our legitimate interest.

Cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies). 

As set out in the UK`s Privacy and Electronic Communications Regulations (“PECD”)and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the Cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

Hosting 

To provide our website, we use the services of WordPress by Automattic Inc, who process all data to be processed in connection with the operation of our website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website.

Third-party services and content

We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services (“content”). 

This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content. 

The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any,

• Tag Management: Google Tag Manager and Google Site Tag by Google LLC,
• Fonts: Google Fonts by Google LLC and Font Awesome by Fonticons Inc,
• Maps: Google Maps by Google LLC,
• Forms: WPForms by WPForms, LLC.
• Analytics

We use Google Analytics of Google LLC which means that the data collected can in principle be transmitted to a Google server in the USA, whereby the IP addresses are anonymised by means of IP anonymisation so that an allocation is not possible. Google analytics places cookies. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You can object to the collection and processing of this data by Google Analytics by setting an opt-out cookie that prevents the future collection of your data when you visit this website: http://tools.google.com/dlpage/gaoptout?hl=en. The legal basis for the use of Google Analytics is based on your consent.

Data we collect directly

Contacting us

Personal data is processed depending on the contact method. In addition to your name and email address, IP address or phone number, we usually collect the context of your message, which may also include certain Personal Data. The personal data collected when you contact us is used to process your request and the legal basis is your consent. 

If you contact or connect with us via the social media platforms on which we are present (currently, Facebook and Instagram) we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual service, if any.

Online appointment booking 

We use the service of Fresha for the simplified booking of appointments. By using this service, data is transferred to Fresha. The processing of the data entered via Fresha is thus exclusively based on a legitimate interest of simplified appointment arrangement. The data entered by you remains with us until you request us to delete it or the purpose for storing the data no longer applies.

Payment 

The provision of payment details is subject to our payment processor Square and does currently not take place through our website. For further information, please refer to Square`s Privacy Policy by clicking on the above link. The legal basis for the data processing is the fulfilment of our contractual obligations and the fulfilment of our legal obligations.

Provision of contractual services 

We process the Personal Data involved in your use of our services in order to be able to provide our contractual services. This includes in particular our support, correspondence with you, invoicing, fulfilment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations.

Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest. 

Comments in our Blog

When you leave comments in our blog or posts, your IP address, your Name, and e-mail address are stored on the basis of our legitimate interests and our contractual obligations to you. This is done for our security in case someone leaves unlawful content in comments and posts. In this case, we can be prosecuted for the comment or post and are therefore interested in the identity of the author. 

Within the blog you may be able to display certain profile information, share certain details, engage with others, exchange knowledge and insights, post and view relevant content. It’s your choice whether to include sensitive information on your comment and to make that sensitive information public. Please do not post or add Personal Data to your comment that you would not want to be available.

Marketing 

We are entitled to contact you for these purposes via the communication channels you have given your consent to. Our direct marketing typically takes the form of e-mail but may also include other less traditional or emerging channels including social media. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will also include a means by which you may unsubscribe or opt out. 

General Principles

Who receives my data?

Within Flawless Aesthetics, those that need your data to fulfil our contractual and legal obligations will receive access to it.

Processors used by us may also receive data for these purposes. These are companies in the categories of IT services, telecommunications, and sales and marketing. Where we use processors to provide our services, we take appropriate legal precautions and corresponding technical and organisational measures to ensure the protection of personal data in accordance with the relevant legal provisions.

Data is only passed on to third parties within the framework of legal requirements. We only pass on users’ data to third parties if this is necessary, for example, for contractual purposes or on the basis of legitimate interests in the economic and effective operation of our business or you have consented to the transfer of data. 

How long will my data be stored?

As far as necessary, we process and store your personal data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract.

In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods and HMRC, among others. The retention and documentation periods specified there are two to 6 years.

How do we secure your data? 

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of content or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website. 

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

Are data transferred to a third country or to an international organisation?

Your data is not transferred to third countries (countries outside the UK and the EEA).

Special Category Data

Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.

Minors

We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

Automated decision-making

Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.

Do Not Sell

We do not sell your Personal Data.

Your Rights and Privileges 

Privacy rights 

Under the DPA and GDPR, you can exercise the following rights:

• Right to information
• Right to rectification
• Right to object to processing
• Right to deletion
• Right to data portability
• Right of objection
• Right to withdraw consent
• Right to complain to a supervisory authority
• Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

Updating your information

If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us. 

Withdrawing your consent 

You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Access Request 

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Scotland is: The Information Commissioner’s Office – Scotland, Queen Elizabeth House, Sibbald Walk, Edinburgh, EH8 8FT, Telephone: 0303 123 1115 www.ico.org.uk

Changes and Questions

We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy or materially change our use of your Personal Data, we will revise this Privacy Policy accordingly and also change the effective date at the end of this section. We encourage you to periodically review this Privacy Policy to be informed of how we use and protect your Personal Data. If you would like to contact us regarding our privacy practices for any reason, please contact us.

Effective Date

Monday, 17 April 2023