Hair Management understands that your privacy is important and that you care about how your personal data is used and shared online. We respect the privacy of our clients.
We are committed to respecting, securing, and protecting your privacy and private data. We are also committed to being transparent about what we collect from you and how we use it.
This privacy notice, which covers your use of our services and our website, provides you with information about what personal data we collect, how we use your data, how we ensure your privacy is maintained, and your legal rights relating to your personal data.
Who We Are
We are Hair Management Ltd. Our registered office address is Sovereign House, 12 Warwick Street, Coventry, West Midlands, CV5 6ET.
You can contact us by:
■ Telephone – 01926 426675
■ Email – firstname.lastname@example.org
■ Post – Hair Management Ltd, c/o Nuffield Wellbeing Centre, Macbeth Approach, Warwick Gates, Warwickshire, CV34 6AD.
Under the General Data Protection Regulation (GDPR) and The Data Protection Act 2018 (DPA) you have a number of rights with regard to your personal data; which this policy and our use of your data has been designed to uphold:
■ Right to be informed – you have the right to be informed about our collection and use of your personal data.
■ Right of access – you have the right to request a copy of the information that we hold about you. You can do this by contacting us using the above details.
■ Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
■ Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
■ Right to restriction of processing – where certain conditions apply, you have a right to restrict our processing.
■ Right of portability – you have the right to have the data we hold about you transferred to another organisation.
■ Right to object – you have the right to object to certain types of processing (such as direct marketing).
If you have cause for complaint about our use of your data, or you would like to exercise any of your rights, then please contact us using the details provided in Section 1 and we will do our best to solve the problem for you.
If we are unable to help, or you aren’t satisfied with our response, you also have the right to lodge a complaint with the UK’s supervisory authority – The Information Commissioner’s Office (ICO). The ICO can be contacted:
■ By post – The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
■ By telephone – 0303 123 1113
■ Via its website – www.ico.org.uk
What Data Do We Collect from You?
We collect some data automatically from you when you use our website. That information is:
■ Your IP address, browser type and version, time zone setting, browser plug-in types, geolocation information about where you might be, operating system and version.
■ Your URL clickstreams (the path you take through our site), products/services viewed, page response times, download errors, how long you stay on our pages, what you do on those pages, how often, and other actions.
If you use the contact form on our website we will collect your name and email address in addition to the automatically collected information above.
If you become a client we will collect data directly from you. The data that we collect will be:
■ Contact Details – Your name, address, email address and telephone numbers.
■ Skin Test History – If you have hair colouring from us we’re legally obliged to perform a skin allergy test within the last 12 months before colouring. We store the result of this to avoid repeating the test unnecessarily.
■ Purchase & Appointment History – We store details of your previous and future appointments and purchase history, including payment details.
How We Use Your Data
Data protection law means that we can only use your data for certain reasons and where we have a legal basis to do so. Below are the reasons for which we process your data, and the legal basis we rely on. We explain what the legal basis means in the next section.
■ Providing Our Services: We will use your contact details and previous history to provide our services to you. Our legal basis for this is contractual obligation (see below).
Where we are colouring hair we make an allergy test in order to provide a safe service to you. This is a special category of data under data protection law, and we will only process this with your explicit consent.
We send appointment reminders by SMS and/or email. Our basis for doing this is legitimate interests. Under PECR rules these are service messages to an existing customer – you can always update your preferences to opt out of these using the details above.
■ Answering Your Queries & Customer Support: We will use your email and contact details to answer your contact requests and queries. Our legal basis for doing so is legitimate interest.
■ Keeping Our Website Running: providing and managing your access to our website and services, personalising and tailoring your experience on our website and services. Our legal basis for this is legitimate interest (see below).
■ Marketing Purposes: We may send you emails and messages about our services and content and keep in touch with you generally, but only with your agreement. You will always be able to unsubscribe from these. Our legal basis for doing that is consent (see below).
We have identified a legal basis for each of our purposes in paragraph 4. This is what they mean:
Processing your data is necessary for a contract you have with us, or because we have asked you to take specific steps before entering into that contract.
■ You have given clear consent for you to process your personal data for a specific purpose.
■ You can always withdraw your consent. You can do this by clicking on unsubscribe in any marketing email we send, or by getting in touch via the contact details in paragraph 1.
■ If you withdraw your consent and we have no other legal basis for processing your data we will stop. If we do have another legal basis we will continue to do so, subject to your legal rights.
Processing your data is necessary for our legitimate interests or the legitimate interests of a third party, provided those interests are not outweighed by your rights and interests. These legitimate interests are:
■ gaining insights from your behaviour on our website
■ delivering, developing and improving our service
■ enabling us to enhance, customise or modify our services and comms
■ enhancing data and physical security
■ promoting our products, services and business.
■ responding to customer enquiries, contact requests and promoting our services.
■ In each case, these legitimate interests are only valid if they are not outweighed by your rights and interests.
■ You can always object to our processing of your data based on legitimate interest. If you do so and we have no other legal basis for processing your data we will stop. If we do have another legal basis we will continue to do so, subject to your legal rights.
Storing and Sharing Your Data
Data security is very important to us and we take appropriate security measures to safeguard and secure your data which is collected via our website and in providing our services.
Our Data Security policy is inline with industry best practice. All of our paper files are kept safe with physical security and destroyed in line with the retention periods specified below.
We endeavour to keep all of your personal information in the European Economic Area (EEA). The EEA includes all EU Member States plus Norway, Iceland and Liechtenstein.
In limited, and necessary, circumstances your information may be transferred outside of the EEA; this will only happen where it can’t be avoided. Where this does happen, we will put special protections in place. We will only move data to countries or organisations:
■ Where the EU Commission has deemed their data protection measures to be adequate;
■ Or under a contract which enforces the EU Commission approved “standard data protection clauses” which can be viewed at http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.
We will never sell or otherwise transfer any of your personal medical data to any third party, except in the event of an emergency, and then only to a medical professional to protect your vital interests.
We will never sell or otherwise transfer or disclose your other personal data to any third party except:
■ We may sometimes contract with trusted service providers to provide goods and services on our behalf. These are generally limited to providing email servers, calendar and appointment booking and payment processing. We may have to transfer your personal data to these companies, or your personal data may pass through them when you deal with us.
■ Where we transfer your data to our trusted service providers we will have confirmed that they will apply data protection and security measures to the same standard we would. We will always impose contractual terms on all of our providers to ensure your data remains secure.
■ In certain limited circumstances we may be legally required to share your personal data – for example where we are involved in legal proceedings, or where we are complying with a court order, regulatory requirement, or government department with appropriate legal authority to compel us to do so.
How Long We Keep Your Data
We do not keep your personal data for any longer than it is necessary in light of the reason(s) for which it was first collected and for our obligation under other laws.
We will keep client data for no longer than 10 years after your last appointment – so that we can efficiently resume providing a service if you return.
At the end of that period your data will be either deleted completely or anonymised.
Exceptions to the above will be:
■ Where you have exercised your right to have the information where it applies.
■ Where the law requires us to keep your data for longer or delete it sooner.
■ Where a legal claim is in progress – we’ll keep your data until that claim is concluded.
Before cookies are placed on your computer or device you will be shown a pop-up requesting your consent to set such cookies as detailed below. By giving us your consent, you are allowing us to provide the best possible experience of our website. You may refuse consent to cookies; however, certain parts of our website may then not function correctly. You can alter your browser settings to refuse all cookies.
All cookies used by and on our website are used in accordance with the current cookie law.
The cookies we use on our website are:
These cookies are used to collect information about how visitors use our website and WordPress blog. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.
Changes to Our Privacy Notice
We may change this privacy notice from time to time (for example, if the law changes). Any changes will be immediately posted on our site. We recommend you check the privacy notice regularly to remain up to date.
This privacy notice was last updated in May 2018.