Privacy Policy

This policy is correct at the time of submission 24/05/2018

The Hair Club London LLP(Company number OC401897) is fully committed to protecting your personal data. This policy statement will inform you as to how we look at, manage and store your personal data and tell you about your privacy rights and how the law protects you in line with the new GDPR legislation.

 

THE PURPOSE OF THIS POLICY:

This GDPR and privacy policy aims to provide you the information on how we collect, store and process all the personal data you provide when you visit our salon. This includes visits to our website, making appointments by phone or booking online plus also covers any newsletters, reward cards and booking made through third parties.

Access to our website is unrestricted so is accessible to everyone including children but the Hair Club London LLP does not knowingly collect data relating to children or vulnerable adults.

The Hair Club London LLP website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

In the event that we do collect your data it is important that you fully understand our GDPR Privacy policy and understand that we will not use or sell your information to any third parties but we may use your data for internal purposes such as market research but in this event when we are collecting or processing personal data about you will be made fully aware of how and why we are using your data.

 

GDPR PRIVACY MANAGER

THE HAIR CLUB LONDON LLP is the data controller and responsible for your personal data. THE HAIR CLUB LONDON LLP have designated GDPR Data privacy manager who is responsible for the implementation of the policy and answering any questions you may have regarding this policy this policy forms part of THE HAIR CLUB LONDON LLP’s Quality Management System.The current GDPR Data Privacy Manager is Mr Mark Hart who can be contacted via the salon.

If you believe that any part of thisGDPR Privacy policy is unfair or incorrect 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).

 

The Hair Club London LLP reserves the right to amend this GDPR Privacy Policy at any time but never to reduce the level of protection of your data. All changes will be highlighted and everyone affected will be notified.

It is also 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 and/or inform us if you wish to have your personal data removed from our systems more information regarding how to do this is included within this policy.

 

The information and data we collect about ‘you’ the client:

The Hair Club London LLP will in the course of its operation collect personal data, personal information or any other information about an individual from which that person can or could be identified. It does not include data where the identity has been removed this is regarded as ‘anonymous data’.

THE HAIR CLUB LONDON LLP may collect, use, store and transfer different kinds of personal data about you which are explained below:

Identity Data – includes first name, last name and/or similar identifier, title, date of birth and gender.

Contact Data – includes billing address, delivery address, email address and telephone numbers.

Transaction Data- includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data- includes internet protocol (IP) address, browser type, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Individual Purchase Data- including purchases or orders made personal preferences, feedback and survey responses.

Medical and Allergy Data– includes allergy test information and details of any medical conditions that might affect services

Company Usage Data– includes information about how you use our website, products and services.

Marketing and Communications Data- includes your preferences in receiving marketing from The Hair Club London LLP.

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 website feature. 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.Except for health information and Allergy Test Data, we do not collect any special categories of personal data about you. Nor do we collect any information about criminal convictions and offences.

 

If you fail to provide personal data:

Where we need to collect personal data by law, or under the terms of an agreement 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. In this case The Hair Club LLP reserve the right to cancel the agreement between us but we will notify you if this is the case at the time.

 

How THE HAIR CLUB LONDON LLP collects your data:

THEhAIR cLUB LONDON LLP usesvarious different methods of collecting data from you including:

 

Direct Interactions.

You may give us your Identity, Contact details and anyMedical and allergy Test Data. This information can be used to:

  • Make an appointment;
  • Purchase our products or services;
  • Accept our rewards card;
  • Request information on products and/or services;
  • Enter a competition, promotion or survey; or
  • Giving the Hair Club London LLP feedback.

 

Automated Interactions:

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Access to our website is unrestricted so is accessible to everyone including children but the Hair Club London LLP does not knowingly collect data relating to children or venerable adults.

The Hair Club London LLP website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

Third parties Interactions.

We may receive personal data about you from various third parties including:

  • Technical Data from analytics providers such as Google and Facebook;
  • Identity, Contact, Technical, Profile, Usage and Transaction Data from providers of technical, payment and delivery services.

 

How THE HAIR CLUB LONDON LLP uses your data

THE HAIR CLUB LONDON LLP will only use your personal data when lawful to do so.

In most circumstance we will use your data for the following reasons:

To make, confirm or change bookings, to receive payment, to discuss services, to request feedback and reviews, to inform you of events or promotions, to confirm medical and allergy information, to notify of any policy or salon changes,to improve customer relations, to comply with legal and or regulatory obligation, any other THE HAIR CLUB LONDON LLP Business that may relate to you the individual including emergencies.

The Hair Club London LLPdo not rely on consent as a legal basis for processing your personal data other than to send marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

The lawful Basis and legitimate reasons for the usage of this data is for the following reasons:to comply with legal obligations, to improve customer service, Internal market research and company analytical information all on the basis of improving the overall customer experience at THE HAIR CLUB LONDON LLP.

 

Direct marketing:

From time to time THE HAIR CLUB LLP with make contact with you directly via, telephone, email, post, text message or social media to promote products and services with a view to improving the customer service and experience. You have the legal right to OPT OUT of these communications.

To do so you can call the Salon directly, E-mail, Text or send a letter. Once the salon receives your opt out information we will confirm you have been removed from any further marketing material. Opting out of receiving marketing information will not OPT you out from receiving contact from the salon regarding appointments, changes to policies etc.

 

Third Party Marketing:

THE HAIR CLUB LONDON LLP will ask for your consent before we share your personal data with any third parties for marketing purposes and will not sell or

 

International Data Transfer:

THE HAIR CLUB LONDON LLP do not currently transfer your personal data outside the European Economic Area (EEA)

 

Data Security:

THE HAIR CLUB LONDON LLP have appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition THE HAIR CLUB LONDON LLP limits access to your personal data to those employees, agents, contractors and other third parties who have read and signed to agree to comply with THE HAIR CLUB LONDON LLP’s GDPR Privacy Policy. All personnel will only process your personal data on the instructions of the Directors of the Business and all are subject to a duty of confidentiality.

We will notify you and any applicable regulator of a breach where we are legally required to do so.

 

Data storage periods:

THE HAIR CLUB LONDON LLP will only retain your personal data for as long as necessary to fulfil the purposes it was collected 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 as follows:

Personal data will be held by THE HAIR CLUB LONDON LLP for as long as you remain an active client at that salon. THE HAIRCLUB LONDON LLP considers activity to be purchasing products or services more than once over a 12 month period. If this is not the case then you cease to be considered an active client and you will be removed from the systems, THE HAIR CLUB LONDON LLP will still retain some of your details to ensure that we comply with our legal obligations and legitimate business interests.

If you choose you can ask THE HAIR CLUB LONDON LLP to delete your data at any time using the same procedures as the Opting out of marketing.

In some circumstances we may anonymise your personal data (so that it can no longer be identified as your data) 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 the following rights under data protection laws and GDPR legislation in relation to your personal data:

  • To request access to your personal data
  • To request correction of your personal data
  • To request erasure of your personal data
  • To object to processing of your personal data
  • To request restriction of processing your personal data
  • To request transfer of your personal data
  • To withdraw consent

You can check and update your personal data each time you visit THE HAIR CLUB LONDON LLP.

 

Response time to requests:

THE HAIR CLUB LONDON LLP will attempt to deal with all correspondence and request as quickly as possible but reserve the right to make contact and comply within 30 days.

 

Data Security Breach protocol:

If THE HAIR CLUB LONDON LLP believes a breach has occurred it will contact you immediately.

You will be informed of the level ofbreach whilst THE HAIR CLUB LONDON LLP simultaneously deals with the breach using its internal procedures. If you believe that you have identified a breach then please contact Mark Hart via the salon.

 

End of Policy

If you believe that any part of thisGDPR Privacy policy is unfair or incorrect 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).