FACE RESTORATION LTD respects your privacy and is committed to protecting your personal data. We want to be transparent with you about how we collect and use your personal data in your dealings with us and your use of our Services (“Services”) and tell you about your privacy rights and how the law protects you.
- Who we are and how to contact us
- Your rights relating to your personal data
- Marketing communications preferences
- What personal data we collect
- How we use your Personal data and why
- What our “legal basis” is
- What happens when you do not provide necessary personal data
- Personal data and Third-Party Sources
- Who we share your personal data with
- Data transfers
- How we keep your personal data secure
- How long we store your personal data
- Third party links
1. Who we are and how to contact us
Who we are: FACE RESTORATION LTD with registered address 22-26 King Street, King’s Lynn, Norfolk, England, PE30 1HJ.
How to contact us: Please email: firstname.lastname@example.org
2. Your rights relating to your personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data 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 data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to the processing of your personal data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing 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 data for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data. We will provide to you, or a third party you have chosen, your Personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent. This right only exists where we are relying on consent to process your personal data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Services. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights:
If you want to exercise any of the rights described above, please contact us using the contact details shown under “Who We Are and How to Contact Us”.
Typically, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, 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.
If you feel that your complaint has not been adequately resolved, please note that the Data Protection Act 2018 gives you the right to contact the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk).
4. Marketing Communications preference
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you and/or by contacting us at any time using the contact details shown under “Who we are and how to contact us”.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of Purchases or Services where we require your personal data to complete your order.
5. What personal data we collect
All the personal data we collect, both from you and from third parties about you, is outlined in the table below.
Before you read this table, it might be useful to explain what “personal data” is. Personal information means any information relating to an identified or identifiable natural person; an identifiable person is one who can be directly or indirectly identified by reference to an identifier such as name, an identification number, location data, online identifier or to one or more factors specific to the physical physiological, genetic, mental, economic, cultural, or social identity of that person.
It does not include ‘anonymous data’ (i.e. information where the identity of an individual has been permanently removed). However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e. information which alone does not identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).
|Category of personal data collected||What this means|
|Identity data||First name, surname, marital status, title, date of birth and gender.|
|Contact data||Your home address, work address, billing address, email address and telephone numbers.|
|Financial data||Your payment card details. Note, that we pass any financial data we receive from you immediately to our third-party payment processors. We do not store any of your financial data.|
|Transaction data||Details about payments to and from you regarding other services you have purchased from us.|
|Marketing and communications data||Your preferences in receiving marketing from us and your communication preferences.|
|Behavioural data||Inferred or assumed information relating to your behaviour and interests based on your online activity and use of our services.|
|Technical data||Internet Protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, platform and other technology on the devices you use to access this website or use our services.|
|Allergy data||Information about allergies, intolerances and/or preferences you have.|
6. How we use your personal data and why
We will only use your Personal data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
7. What is our “legal basis” for processing your personal data?
In respect of each of the purposes for which we use your personal data, most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract we are about to enter into or have entered into with you (“contractual necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“legitimate interests”). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“compliance withlaw”).
- Where we have your specific consent to carry out the processing for the purpose in question (“consent”).
Generally, we do not rely on your consent as a legal basis for using your personal data other than in the context of direct marketing communications.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant purposes for which we use your personal data.
To process advance payments for bookings · Identity data · Contact data · Financial data · Transaction data To process your order to secure a reservation or to pay, or part pay, for a reservation in advance and allocate such payments correctly. Contractual necessity To improve our services · Behavioural data · Technical data To monitor use of our Services to improve our Services, to help operate our Services more efficiently, and to improve your experience. Legitimate interests We have a legitimate commercial interest in ensuring that our sites operate as efficiently as possible and that we improve our sites based on information we learn from our users’ use of our sites. To provide your order to you and record your food allergies, intolerances and preferences · Allergy data To ensure that we take into account information about your food allergies, intolerances and/or preferences when preparing and delivering your order to you. Explicit consent We obtain your explicit consent to use data relating to your food allergies and intolerances. Legitimate interests We have a legitimate interest in taking your food preferences into account when preparing and delivering your order to you, to ensure that you are satisfied with the services you receive from us.
|Purpose||Category(ies) of personal data involved||Why do we do this||Our legal basis for this use of data|
|CCTV/ security||Identity data||Internal & External Security||Legitimate interests. We have a legitimate interest in protecting our patients and the general public, and providing security for those using our facilities.|
|Reservations / bookings||Identity data|
Contact data Transaction data
|To secure and manage reservations, and to settle accounts.||Contractual necessity|
Contact data Marketing and communications data
|To send you newsletters and event information which we think may be of interest to you.||Consent. We obtain opt-in consent to send marketing communications to you.|
|To process payments||Identity data|
Contact data Financial data Transaction data
|To process and deliver your orders and/or services.||Contractual necessity|
|To improve our services||Behavioural data Technical data||To monitor use of our Services to improve our Services, to help operate our Services more efficiently, and to improve your experience.||Legitimate interests. We have a legitimate commercial interest in ensuring that our sites operate as efficiently as possible and that we improve our sites based on information we learn from our users’ use of our sites.|
|To provide food and/or beverages and record your food allergies, intolerances and preferences||Allergy data||To ensure that we take into account information about your food allergies, intolerances and/or preferences when preparing and providing food and/or beverages to you.||Explicit consent.|
We obtain your explicit consent to use data relating to your food allergies and intolerances.
We have a legitimate interest in taking your food preferences into account when preparing and delivering food and/or beverages to you, to ensure that you are satisfied with the services you receive from us.
8. What happens when you do not provide necessary personal data?
Where we need to process your personal data either to comply with law, or to perform 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 the functionalities of the Services).
In this case, we may have to stop you using our services but we will notify you if this is the case at the time.
9. Personal data from third party sources
In addition to the personal data that we collect directly from you (as described in the section immediately above this one), we also collect certain aspects of your personal data from third party sources.
These sources are broken down in the table below, together with a description of whether they are publicly available or not.
|Third Party data source||Publicly available?||Category(ies) or other types of personal data received|
|Online booking platforms when in effect||No||Identity data|
|Analytics providers||No||Behavioural data|
We may collect information using “cookies”.
What are cookies?
Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our sites.
We use two broad categories of cookies:
First party cookies – served directly by us to your computer or mobile device; and
Third party cookies – served by our partners or service providers on our sites.
Cookies we use:
Our sites use the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
|Essential cookies||These cookies are essential to provide you with services available through our sites and to enable you to use some of its features.|
|Functionality cookies||These cookies allow our sites to remember choices you make when you use our sites, such as remembering your language preferences. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our sites.|
|Analytics and performance cookies||These cookies are used to collect information about traffic to our sites and how users use our sites. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our sites. The information collected is aggregated and anonymous. It includes the number of visitors to our sites, the websites that referred them to our sites, the pages they visited on our sites, what time of day they visited our sites, whether they have visited our Sites before, and other similar information. We use this information to help operate our sites more efficiently, to gather broad demographic information and to monitor the level of activity on our sites.|
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our sites work. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html
|Social media cookies||These cookies are used when you share information using a social media sharing button or “like” button on our sites or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.|
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our sites. For example, our sites not remembering your language setting.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them. Visit www.allaboutcookies.org and www.youronlinechoices.com. You can also prevent the use of Google Analytics relating to your use of our sites by downloading and installing the browser plugin available via this link: https://tools/google.com/dlpage/gaoptout?hl=en=GB.
11. Who we share your personal data with
The table below describes who we share your Personal data with, what we share and why we share it.
|Recipients||Category(ies) of Personal data We Share||Why we share it|
|Payment systems||Financial data||To process payments via third party platforms in a PCI compliant manner.|
|Reservations platforms||Identity data|
|Our service providers provide us with IT systems that help manage our bookings and reservations process.|
|Marketing digital platforms||Identity data|
|Our service providers administer our marketing communications with Members who have opted-in to receive such communications from us.|
|Courier companies||Identity data|
|We share only the essential details with third party couriers when delivering physical content to you from time to time.|
|Printing companies||Identity data|
|We share only the essential details with third party printers when we print physical content that requires your name and address (letters/envelopes) to you from time to time.|
12. Data transfers
As you can see from the above, we share your personal data with our affiliated companies and certain external third parties.
We endeavour to ensure that people to whom we provide personal data hold it subject to appropriate safeguards and controls. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring safeguards are implemented (explained below).
13. How we keep your personal data secure
We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We store all the personal information you provide on secure password and firewall protected servers.
We limit access to your personal data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected personal data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your personal data.
14. How long we store your personal data
We will only retain your personal data for so long as we reasonably need to use it for the purposes set out above in “How we use your personal data and why”, unless a longer retention period is required by law (for example for regulatory purposes).
15. Third party links