PRIVACY POLICY
Introduction
The following privacy notice outlines how Moreton Place Beauty & Wellbeing collects, uses, protects and transfers your personal data.
The data protection officer/data owner for the organisation is Angela Burnett. You can contact the data protection officer/data owner by sending an email to info@moretonplace.co.uk or writing to Moreton Place Beauty & Wellbeing, 40 Moreton Street, London, SW1V 2PB for the attention of Angela Burnett.
Personal data collected
The personal data that we collect is:
- Name
- Home address (mailing & billing address)
- Email Address
- Date of birth
- Phone number
- Health information
- Payment information
- Details of your interactions with us through phone, email, social media or the website through comments (we would only collect data if you request a follow up mail notification) and enquiry/contact forms.
- CCTV images/footage may be collected when you visit for the safety and security of our customers, staff and business.
Purpose and Legal Basis for Processing Your Data
Moreton Place Beauty & Wellbeing take 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.
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?
Moreton Place Beauty & Wellbeing, 40 Moreton Street, London, SW1V 2PB, 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 the salon and have access to personal information only in cases that customer support or troubleshooting is required by Moreton Place Beauty & Wellbeing. 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, requests to cancel or change bookings as well as product/gift voucher requests and treatment/product advice.
- 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.
- Improve the service (and/or products) we provide.
- Detect crime – CCTV images and/or footage are retained for 30 days and then deleted. Please note if we are requested to provide CCTV images and/or footage of you or any other personal information relating to you by the police we are obliged to do so. If CCTV images and/or footage are required for an investigation they will be retained until after the investigation has been concluded.
Your rights as the individual
If your personal data is held by Moreton Place Beauty & Wellbeing, 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 Moreton Place Beauty & Wellbeing 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 to receive 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 Moreton Place Beauty & Wellbeing to another organisation in an easily readable format.
- To object to direct marketing from us.
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. Moreton Place Beauty & Wellbeing asks for consent prior to gathering and processing this information. At any time after giving consent, you can withdraw your 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 Moreton Place Beauty & Wellbeing, 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, Mailchimp (our email marketing platform, only your email address is stored here if you opt into email marketing) as well as some level of computer record keeping.
Moreton Place Beauty & Wellbeing gives you access to information about your account and bookings through Phorest software, for the limited purpose of viewing and updating that information.
Children’s Privacy
Moreton Place Beauty & Wellbeing does not collect the personal data of children under the age of 16 without parental or guardian consent. If you believe that we hold any information about a child under the age of 16, please contact Moreton Place Beauty & Wellbeing and if we cannot immediately obtain appropriate parental or guardian consent, will remove the personal data from storage.
Data Sharing
Your personal data is shared only with Phorest representatives in cases that customer support and troubleshooting is required for the salon. Moreton Place Beauty & Wellbeing does 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
Data processors are third parties who provide some elements of our business services for us:
Phorest
Moreton Place Beauty & Wellbeing use software provided by Phorest to manage the salon for appointment scheduling, CRM and SMS marketing.
Mailchimp
Moreton Place Beauty & Wellbeing uses Mailchimp, an online marketing platform, to facilitate their email marketing. When you subscribe to our mailing list, your data (email address) is collected and processed by Mailchimp. You can find their privacy policy here.
You can be removed from our mailing list at any time by clicking on the unsubscribe button contained in each marketing email.
Zoom
Moreton Place Beauty & Wellbeing uses Zoom, a cloud based video conferencing service, to facilitate their virtual services. You can find their privacy policy here.
Couriers
- We share your name and postal address with our couriers to fulfil your product/ gift voucher order(s).
International Institute of Anti-Ageing (IIAA)
- If you order Environ, Advanced Nutrition Programme supplements or Jane Iredale products from our online store and we do not have the items in stock, we may share your name, postal address, telephone and email address with the International Institute of Anti-Ageing to facilitate your order on our behalf. This information will not be stored by them and is only for delivery purposes (name and delivery address will be passed onto their courier provider, email address and phone number might be processed by IIAA and their courier provider to provide you with delivery updates).
How Long Do We Keep Your Data?
Moreton Place Beauty & Wellbeing retains your personal data for as long as necessary to provide you with our services as our client. Moreton Place Beauty & Wellbeing are 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 includes:
- 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 claims
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 Moreton Place Beauty & Wellbeing
In the event that you want to purchase a product or service from Moreton Place Beauty & Wellbeing, certain personal information is required to enter into a contract with you. Moreton Place Beauty & Wellbeing 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 unauthorised 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 salon.
Cookies
- Our website uses cookies, as almost all websites do, to help provide you with the best experience we can. Please see our Cookie Policy for more information.
Links to other websites
- Our website may contain links to other websites of interest. Please note that once you have used these links to leave our site we do not have any control over these websites. Therefore, we cannot be held responsible for the protection and privacy of any information you provide whilst visiting these sites as they are not governed by this privacy statement. You should look at the privacy policies on these websites.
Complaints
In the occurrence that you want to make a complaint about how your personal data was gathered, how it is being processed by Moreton Place Beauty & Wellbeing(or third parties used by Moreton Place Beauty & Wellbeing 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 Moreton Place Beauty & Wellbeing and also the salon Data Protection Officer/ GDPR Owner.
Data Protection Commissioner
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
+44 (0) 303 123 1113
Moreton Place Beauty & Wellbeing Data Protection Officer / GDPR Owner
Angela Burnett
40 Moreton Street, London, SW1V 2PB
0207 821 1020