PURPOSE OF THIS PRIVACY NOTICE
Saba Raja The Home of Aesthetics Limited (Company number 12657589), is the data controller and responsible for your personal data (“The Home of Aesthetics”, “we”, “us” or “our”).
The Home of Aesthetics respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), when you become a customer of The Home of Aesthetics, and/or use our aesthetic services including but not limited to ZO, “Aesthetic Services”, and/or purchase any products that we recommend to you in our clinic (“Products”) and is intended to tell you about your privacy rights and how the law protects you.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
THIRD PARTY LINKS
DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, including sensitive special category data, that may be provided by you when you: (i) correspond with us, for example via SMS, email, telephone, WhatsApp or otherwise; (ii) during consultations and appointments; and/or (iii) when you purchase a Product and/or Aesthetic Service in our clinic.
We have grouped the data types together follows:
- Identity Data includes title, first name, last name, username or similar identifier, date of birth and a before/after photo of you showing the results of the Aesthetic Service and/or Product.
- Contact Data includes home address, email address and telephone numbers.
- Financial Data includes billing address, bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of Products and/or Aesthetic Services you have purchased from us.
- Technical Data includes internet protocol (IP) address, URL, your login data, browser type and version, time zone setting and location, page interaction, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your interests, preferences, feedback/reviews and any survey responses.
- Usage Data includes information about how you use our website, Products and Aesthetic Services (e.g. searches and/or bookings made by you).
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties that may be of interest to you and your communication preferences.
- Special Category Data: includes information revealing racial or ethnic origin (skin types), physical or mental health conditions and facts, allergies, medical conditions, any drugs/prescription details you may be taking.
It is very important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature on our website. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We also collect Special Categories of Personal Data about you (defined above) for the purposes set out below. But we do not collect any information about religious or philosophical beliefs, political opinions, sexual orientation, genetic data, trade union membership, criminal convictions and offences or biometric data.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Products in our clinic or our Aesthetic Services). In this case, we may have to cancel the provision of a Product to you or an Aesthetic Service you have booked with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Financial Data and Special Category Data by corresponding with us online (social media platforms, WhatsApp), post, phone (including sms), email, during consultations/appointments, or otherwise. This includes personal data you provide when you:
- want to make a booking with us
- order Products in our clinic and/or use our Aesthetic Services
- subscribe to newsletters or messages with us;
- request marketing to be sent to you; or
- give us some feedback/a review.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from publicly available sources.
- Technical Data from the following parties:
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you, including processing payments in our clinic and providing you with advice during (and after) your consultation/appointments.
- To upload your details into our appointment booking system in the clinic
- To create statistical information which will help us manage the types of Products offered in our clinic and/or Aesthetic Services we provide and to make improvements to these.
- To manage the effectiveness of our website and deliver this to you.
- To allow you to access any interactive features of the website which may allow you to access your booking information.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where you have given us consent for us to contact you.
- In order to protect your data and your identity.
We will only process Personal Data fairly and lawfully and for specified purposes. The GDPR restricts our actions regarding Personal Data to specified lawful purposes. We can process Special Category Data only if we have a legal ground for processing and one of the specific processing conditions relating to Special Category Data. We identify and document the legal ground and specific processing condition relied on for each processing activity in the table included below.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to collecting Special Category Data or sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer in our clinic/ user of our website||(a) Identity
(c) Special Category
|Performance of a contract with you|
|To process the purchase of your Product and/or Aesthetic Service by:
(a) Collecting payments using card machine
(b) Arranging delivery of Products (where this has been agreed)
(d) Collecting and recovering any money owed to us (where applicable)
(e) Marketing and Communications
(f) Special Category
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a survey, or where you choose to enter a competition
(c) Asking you to use before/after photos and images showing the results of an Aesthetic Service you’ve had with us
(d) Marketing and Communications
(e) Special Category
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/Aesthetic Services)
(d) Consent including pre and post treatment photographs.
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
To monitor our website to make sure it is functioning correctly and to its optimum and be able to correct any issues to improve the customer journey.
(d) Special Category
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant and effective website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
(g) Special Category
|Necessary for our legitimate interests (to study how customers use Products/Aesthetic Services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, Product offering in our clinic/Aesthetic Services, marketing, customer relationships and experiences and send you marketing information about our Product offering and/or Aesthetic Services that may be of interest to you.||(a) Technical
(c) Special Category
|Necessary for our legitimate interests (to define types of customers for Products offered and Aesthetic Services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may use your Identity, Contact, Technical, Usage, Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Products, Aesthetic Services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased Products and/or Aesthetic Services from us and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time [by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by Contacting us at any time].
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- Advertising agencies we choose to work with in order to target specific audiences and make our advertising relevant to individuals who wish to purchase Products in our clinics and Aesthetic Services.
- Other third parties that we work with in order to provide Products and/or Aesthetic Services to you including our third party online booking/appointment system and Delivery/logistics companies who arrange delivery of Products to you (where this has been agreed with us).
- Other third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the European Economic Area (EEA).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by Contacting us. Where we no longer require Special Category Data for the purpose for which it was collected, we will delete it or render it permanently anonymous as soon as possible.
In some circumstances you can ask us to delete your data (see Request erasure below for further information).
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
|Request access…||to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.|
|Request correction…||of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.|
|Request erasure..||of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).|
|Object to processing…||of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.|
|Request the restriction of processing…||of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.|
|Request the transfer…||of your personal information to another party.|
If you wish to exercise any of the rights set out above, please Contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
DATA PRIVACY MANAGER
We have appointed a data privacy manager: who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
- Full name of legal entity: Saba Raja The Home of Aesthetics Limited
- Name or title of Data privacy manager: Saba Raja
- Email address: email@example.com
- Postal address: 24 , Ipswich Road , Norwich NR2 2LZ , Norfolk , UK
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This version was last updated on 17/11/2020.
Website Terms & Conditions
PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY BEFORE USING THIS WEBSITE
Who we are and how to contact us
https://drsabaraja.co.uk is a website operated by Saba Raja The Home of Aesthetics Limited (“We”). We are registered in England and Wales under company number 12657589 and have our registered office and trading address at 24 Ipswich Road, Norwich, Norfolk, United Kingdom, NR2 2LZ. Our VAT number is [VAT NUMBER].
We are a limited company.
To contact us, please email firstname.lastname@example.org or telephone our customer service line on 01603 383 222.
By using our website you accept these terms
If you do not agree to these terms, you must not use our website.
We recommend that you print a copy of these terms for future reference.
There are other terms that may apply to you
We may make changes to these terms
We amend these terms from time to time. Every time you wish to use our website, please check these terms to ensure you understand the terms that apply at that time.
We may make changes to our website
We may update and change our website from time to time to reflect changes to our service offering, our users’ needs and our business priorities.
We may suspend or withdraw our website
Our website is made available free of charge.
We do not guarantee that our website, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of our website for business and operational reasons. We will try to give you reasonable notice of any suspension or withdrawal.
We may transfer this agreement to someone else
We may transfer our rights and obligations under these terms to another organisation. We will always tell you in writing if this happens and we will ensure that the transfer will not affect your rights under the contract.
Our website is only for users in the UK
Our website is directed to people residing in the United Kingdom. We do not represent that content available on or through our website is appropriate for use or available in other locations.
How you may use material on our website
We are the owner or the licensee of all intellectual property rights in our website, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.
You may print off one copy, and may download extracts, of any page(s) from our website for your personal use and you may draw the attention of others within your organisation to content posted on our website.
You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.
Our status (and that of any identified contributors) as the authors of content on our website must always be acknowledged.
You must not use any part of the content on our website for commercial purposes without obtaining a licence to do so from us or our licensors.
Do not rely on information on this website
The content on our website is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our website.
Although we make reasonable efforts to update the information on our website, we make no representations, warranties or guarantees, whether express or implied, that the content on our website is accurate, complete or up to date.
We are not responsible for websites we link to
Where our website contains links to other websites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them.
We have no control over the contents of those websites or resources.
User-generated content is not approved by us
This website may include feedback/reviews uploaded by other users of the website which have not been verified or approved by us. The views expressed by other users on our website do not represent our views or values.
How to complain about content uploaded by other users
If you wish to complain about content uploaded by other users, please contact us on 01603 383 222.
Our responsibility for loss or damage suffered by you
- We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors and for fraud or fraudulent misrepresentation.
- Different limitations and exclusions of liability will apply to liability arising as a result of our supply of any Products and/or Aesthetic Services to you, which will be set out in our Terms and Conditions of supply.
- Please note that we only provide our website for domestic and private use. You agree not to use our website for any commercial or business purposes.
How we may use your personal information
Uploading content to our website
You warrant that any such contribution does comply with those standards, and you will be liable to us and indemnify us for any breach of that warranty. This means you will be responsible for any loss or damage we suffer as a result of your breach of warranty.
Any content you upload to our website will be considered non-confidential and non-proprietary. You retain all of your ownership rights in your content, but you are required to grant us and other users of our website a limited licence to use, store and copy that content and to distribute and make it available to third parties.
We are not responsible for viruses and you must not introduce them
We do not guarantee that our website will be secure or free from bugs or viruses.
You are responsible for configuring your information technology, computer programmes and platform to access our website. You should use your own virus protection software.
You must not misuse our website by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful. You must not attempt to gain unauthorised access to our website, the server on which our website is stored, or any server, computer or database connected to our website. You must not attack our website via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities, and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our website will cease immediately.
Rules about linking to our website
You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it.
You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.
You must not establish a link to our website in any website that is not owned by you.
Our website must not be framed on any other website, nor may you create a link to any part of our website other than the home page.
We reserve the right to withdraw linking permission without notice.
If you wish to link to or make any use of content on our website other than that set out above, please contact email@example.com.
Which country’s laws apply to any disputes?