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    Aesthetics Health Barnet Enfield London

      

    GDPR PRIVACY POLICY FOR WEBSITE

      


     

    This   privacy policy tells you what will happen to any personal data that you   provide to (The World of Work Limited t/a WOW Health & Aesthetics Clinic)   as a result of using this website or contacting this organisation. We fully   understand that your privacy is important to you and that you care about how   your personal data is used and shared online and we will take account of, and   respect, your concerns.

     

    This   policy explains how we will use, and protect, the information that we gather,   whether it be through this website, by way of telephone or personal   conversations or through our normal business contacts with you. Please read   this privacy policy carefully and ensure that you understand it. Details are   given below of contacts should you wish to ask questions but please note that   acceptance of this privacy policy and our cookie policy (see “Cookies” below)   is required to make full use of our site.

     

    Our details

     

     

    Organisation’s   name


    The   World of Work Limited t/a WOW Health & Aesthetics Clinic

    Address


    13   Genotin Terrace


     

     Telephone   number


    0203   793 7220


     

     

    Email   address 


    bookings@wowhealthaestheticsclinic.pro


     

    For   you data queries please contact (Myrofora   Georgiou) can be contacted at (bookings@wowhealthaestheticsclinic.pro).

     

    Your rights

     

    Under   the General Data Protection Regulation (GDPR), you have the right to be   informed about:

    • the        collection and use of your personal data
    • our        purposes for processing that data
    • the        retention periods for storing your data (or a guarantee that it will be kept only for as long as necessary)
    • who        it will be shared with (both in this country and, if applicable, in others: in this case, we will inform you of the safeguards which are applied in that country)
    • the        legal basis under which we process your data
    • the        right to withdraw your consent (if consent is the legal basis for processing)
    • our        “legitimate interest” in processing your data (if that interest is the legal basis for processing)
    • details    of any data we collect about you from a third party (such as publicly-available information)
    • the        right to lodge a complaint with the ICO
    • details  of the existence of automated decision-making, including profiling (if        applicable).

    You   also have the right to information that is concise, transparent,   intelligible, easily accessible and presented to you in clear and plain   language rather than in “legalese”. We would encourage you to get in touch   with the contact given above if you have any questions about this policy   statement or our procedures with regard to data processing. This will not in   any way affect your right (mentioned above) to complain to the ICO.

    Finally,   we commit to informing you if, at any time, we update our privacy information   and always to seek permission if we plan to use your personal data for a new   purpose.

      

    The information we   collect

     

    We   process and store details of your*:

    • name
    • chosen   mode of address (Mrs, Ms, etc)
    • job  title
    • date  of birth
    • address
    • IP   address
    • email address
    • username(s)

    (*delete if necessary).

    These   details will typically be provided when you take out a subscription or sign   up to receive a newsletter or future details of our products/services. We   only keep them for as long as necessary and you may, at any time, contact us   to ask for them to be removed (see “the right to be forgotten” below).

    (Where the   organisation collects sensitive personal information — such as biometric data   or details of racial or ethnic origin, religious or philosophical beliefs or   trade union membership — or financial information, it should make clear the   extra levels of security — such as encryption — that will be applied to its   protection.)

     

    Why do we need this   information?

     

    We   use the information that we collect and store about you to:

    • provide our products/services
    • manage invoices and accounts
    • deliver marketing and events information
    • invite participation in polls and surveys.

    (Note: this is not an   exhaustive list and should be amended or added to, to reflect the   organisation’s business model.)

     

    The legal basis under which we collect and store data

     

    There   are six possible legal grounds under the GDPR. These are:

    1.   consent

    2.   fulfilment of a contact

    3.   legitimate interests

    4.   vital interests

    5.   public task

    6.   legal obligation.

    Each organisation   must decide which of these applies to the data they process and explain how   and why that is the case. For example, “consent” to use personal data must be   freely given and be provided in an intelligible and easily accessible form,   using clear and plain language (not pre-ticked boxes or any other method of   default consent). It must be as easy to withdraw consent as it is to give it.

    “Legal obligations”   is a lawful basis if an organisation needs to process the personal data to   comply with a common law or statutory obligation. The ICO makes clear that   “you cannot rely on this lawful basis if you have discretion over whether to   process the personal data, or if there is another reasonable way to comply”.

    “Vital interests” is   unlikely to feature in most organisation' routine plans as it covers the need   to process the personal data to protect someone’s life. If the person’s vital   interests can reasonably be protected in another less intrusive way, this   basis will not apply.

    “Public task” is   mainly relevant to public authorities or to organisations that exercise   official authority or carry out tasks in the public interest. Again, to quote   the ICO: “If you could reasonably perform your tasks or exercise your powers   in a less intrusive way, this lawful basis does not apply.”

      

    This leaves   “legitimate interests” as the legal basis most likely to be used, if consent   does not apply. It is the most flexible, and likely to be most appropriate   where you are using people’s data in ways they would reasonably expect and   which have a minimal privacy impact, or where there is a compelling   justification for the processing.

    If you decide that   “legitimate interests” is the legal basis on which you are collecting and   processing personal data, it would be advisable to include in your data   protection policy a statement to the effect that:

    Legal basis —   legitimate interests

    “This   organisation has carried out a legitimate interests assessment (LIA) which   can be seen on request. In doing so, we have checked that the processing is   necessary and that there is no less intrusive way to achieve the same result.   We will only use your data in ways that you would reasonably expect, unless   we have a very good reason. We will not use your data in ways that you would   find intrusive or which could cause you harm and we have considered and   introduced safeguards to reduce the impact where possible.

    If   we process children’s data, we take extra care to make sure we protect their   interests. In using this basis for processing data, we will make sure that   your interests, as protected by the GDPR, are not undermined by our   legitimate interests.”

     

    Applying the data   protection principles

     

    This   organisation is committed to applying the principles set out in the GDPR. To   that end, we will always strive to ensure that:

    • personal        data is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
    • our        procedures are adequate, relevant and limited to what is necessary in relation to the purposes for which they are put in place
    • the        data we collect are accurate and, where necessary, kept up to date, every reasonable step will be taken to ensure that data that are        inaccurate, having regard to the purposes for which they are processed,        are erased or rectified without delay
    • data are kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which they are processed
    • data        are processed in a manner that ensures their appropriate security, including protection against unauthorised or unlawful processing and  against accidental loss, destruction or damage, using appropriate technical or organisational measures.

     

    Better by design

     

    In   applying the above principles, this organisation recognises that it has a   general obligation to implement technical and organisational measures to show   that it has considered and integrated data protection into all data   processing activities. We have built safeguards into products and services   from the earliest stage of development and privacy-friendly default settings   are the norm for all our services. All of our employees are trained in the   requirements of GDPR and as far as possible we aim to ensure that contracts,   website designs, publicity materials and HR policies are all in line with the   GDPR requirements.

     

    Access to your data

     

    On   receipt of a request for access to the data which we hold about you, we will   respond without delay and at the latest within one month of receipt.   Information will be provided free of charge although a reasonable fee may be   applied when a request requires excessive work, particularly if it is   repetitive. This fee will reflect the amount of administrative work involved.

     

    The right to be   forgotten

     

    Also   known as data erasure, the “right to be forgotten” set out in the GDPR   entitles you to ask any data controllers (including this organisation) to   erase your personal data and to cease further dissemination. You can make   such a request either verbally or in writing and we will respond as quickly   as possible, and at the latest within one month. We understand that there is   a particular emphasis on the right to erasure if the request relates to data   collected from children and such requests will always be given the highest   priority.

    Please   note, however, that there are certain circumstances in which the right to   erasure may not apply. These include where processing is necessary for one of   the following reasons:

    • to        comply with a legal obligation
    • to        exercise the right of freedom of expression and information
    • for        the performance of a task carried out in the public interest or in the exercise of official authority
    • for        the establishment, exercise or defence of legal claims.

    In   addition, any organisation is allowed to refuse to comply with a request for   erasure if it is manifestly unfounded or excessive, taking into account   whether the request is repetitive in nature. We will, however, explain and   justify any such refusal.

     

    Right to be informed

     

    Within   one month of collecting your personal data, we will inform you of the   purposes for processing that data, the retention periods and with whom it   will be shared. Any information which is provided to you will be concise,   transparent, intelligible, easily accessible and presented in clear and plain   language.

     

    Right to rectification

     

    Either   verbally or in writing, you may ask for inaccurate personal data to be   rectified, or to be completed if it is partial. We will respond as quickly as   possible and certainly within the one month time period allowed under the   GDPR. In the unlikely event that there is disagreement over the accuracy of   the data, we will do our best to resolve this and you will, of course, have   right to take the matter to the ICO if we cannot reach agreement. If that   situation arises, we are prepared to consider restricting processing of the   contested data during the time it takes to resolve the issue with the ICO.

     

    Children

     

    Under   the GDPR, only children aged 13 or over are able provide their own consent.   For those under this age, we will seek consent from whoever holds parental   responsibility or, if we are using a different legal basis, will inform that   person accordingly. We are fully aware that children have the same rights as   adults over their personal data and are committed to ensuring full protection   for them at all times.

     

    Right to data   portability

     

    This   organisation recognises that, under the GDPR, you must be able to move, copy   or transfer personal data easily from one IT environment to another in a safe   and secure way, without hindrance to usability. The requested information   will be provided free of charge in a structured, commonly used and   machine-readable form. However, it should be noted that the right to data   portability only applies:

    • to personal data an individual has provided to a controller
    • where  the processing is based on the individual’s consent or for the performance of a contract
    • when processing is carried out by automated means.

     

    Right to object

     

    You   have the right to object to:

    • processing based on legitimate interests or the performance of a task in the public        interest/exercise of official authority (including profiling)
    • direct marketing (including profiling)
    • processing for purposes of scientific/historical research and statistics.

    We   will stop processing personal data for direct marketing purposes as soon as   an objection is received.

     

    Automated decision-making and profiling

     

    Profiling   refers to the automated processing of personal data to evaluate certain   things about an individual. Together with making a decision solely by   automated means, it is covered by the GDPR and will require the individual’s   explicit consent. We will only collect the minimum amount of data needed and   will retain it only for as long as is necessary. Anyone affected by an   automatic decision has the right to ask for it to be reconsidered and we have   additional checks in place for profiling/automated decision-making systems to   protect vulnerable groups such as children.

     

    Data breaches

     

    While   we will take all appropriate measures to prevent illegal access to your data,   we have to prepare for that possibility. Should there be a significant data   breach affecting your data and rights, we will notify you (and the ICO) as soon as possible. To minimise any possible danger, we will use encryption   and/or pseudonymisation where it is appropriate to do so. We will also have   backup systems in place in the event that an outside organisation attempts to   disrupt access to our data,

     

    International   transfers

     

    (If an organisation   sends data to countries outside the EU.)

    Given   that all members of the European Economic Area (EEA) (that is, all EU Member   States, plus Norway, Iceland, and Liechtenstein) have to comply with the   Union’s standards on data protection, and particularly with the GDPR, then we   can legally transfer data to those countries. However, if we have reason to   send data to non-EEA countries, we recognise that they must have equivalent   standards in place. This is not a matter for individual organisations to   assess but must be based on, for example, standard data protection clauses in   the form of template transfer clauses adopted by the European Commission or   compliance with an approved Code of Conduct approved by the ICO.

    Should   such transfers take place, we will make it clear which of these provisions we   have adopted to ensure safety. (Among the countries recognised by the   commission as having equivalent standards are Switzerland, New Zealand and   Canada. USA companies that have certified with the EU-US Privacy Shield programme are also considered to be safe   destinations).

     

    Cookies

     

    A   cookie is a small text file placed on your computer or device by our site   when you visit certain parts of it and/or use certain of its features. For   example, we may monitor how many times you visit, which pages you go to,   traffic data, location data, weblogs and other communication data whether   required for billing purposes or otherwise. We may also look at the originating   domain name of a user’s internet service provider, IP address, operating   system and browser type. This information helps us to build a profile of our   users. Where appropriate, this data will be aggregated or statistical, which   means that we will not be able to identify you individually.

    Cookies   are also used to remember your settings (language preference, for example)   and for authentication (so that you do not have to repeatedly sign in). You   can set your browser not to accept cookies and there are a number of websites   which explain how to remove cookies from your browser. However, it is   possible that some of our website features may not function as a result.

     

    Third party websites

     

    Please   note that there are some links on our website to other sites where you may   find useful information. This does not indicate a general endorsement of   those sites and, as we have no control over how data is collected, stored, or   used by other websites, we would advise you to check their privacy policies   before providing any data to them.

     

    Last updated on (13.9.23)   by (Myrofora Georgiou) who can be contacted at (bookings@wowhealthaestheticsclinic.pro).

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