Privacy Policy

This Privacy Policy (the “Policy”) explains how we collect, use, and protect your personal data in compliance with the UK General Data Protection Regulation (“UK GDPR”). This Policy applies to visitors and users (individually, “you”) of our websites and any other online services. Please note that not all services described herein are available in all jurisdictions.

We are committed to safeguarding your privacy. If we request information that can identify you (“personal data”), you can be assured it will be handled in accordance with this Policy.

We may update this Policy periodically by revising this page. Please check back regularly to stay informed about any changes.

Data We Collect

We may collect the following personal data:

Name.
Contact information, including email address and phone number.
Demographic information such as address and postcode.
Technical data, such as IP address, browser type, and information collected via cookies or similar technologies (e.g., Google Analytics).

How We Use Your Data

We process your personal data to provide services, fulfil your requests, and for the following purposes:

Internal record keeping.
Processing orders and obtaining payment.
Improving our products and services.
Sending you updates or marketing communications, if you have opted in.

Lawful Basis for Processing

We process your personal data based on one or more of the following legal grounds:

Consent: Where you have provided explicit consent for specific purposes.
Contractual necessity: To perform a contract with you or take steps at your request before entering a contract.
Legal obligation: To comply with applicable legal requirements.
Legitimate interests: To pursue our legitimate business interests, provided your rights and freedoms are not overridden.

Security Measures

We are committed to ensuring your personal data is secure. We implement appropriate technical and organisational measures to protect against unauthorised access, alteration, disclosure, or destruction of your personal data.

Your Rights

Under UK GDPR, you have the following rights:

Right to Access: Request a copy of the personal data we hold about you.
Right to Rectification: Request corrections to any inaccurate or incomplete data.
Right to Erasure: Request deletion of your personal data under certain circumstances.
Right to Restrict Processing: Request a restriction on how we process your data in specific situations.
Right to Data Portability: Receive your data in a structured, commonly used, and machine-readable format.
Right to Object: Object to processing based on legitimate interests or direct marketing.
Right to Withdraw Consent: Withdraw consent where processing is based on consent.
Right to Complain: Raise a complaint with us directly (see Data Protection Complaints below), or lodge a complaint with the Information Commissioner’s Office (ICO) if you believe your rights have been violated.

Data Protection Complaints

If you believe we have not handled your personal data in line with this Policy or UK data protection law, you can raise a complaint with us directly.

You can submit a complaint through our contact page . Please include enough detail for us to investigate, such as what happened and when.

We will acknowledge your complaint within 30 days of receiving it. We will then investigate without undue delay and let you know the outcome, along with any action we have taken as a result.

If you are not satisfied with how we have handled your complaint, or you would prefer to raise it directly with the regulator, you can contact the Information Commissioner’s Office (ICO):

Website: ico.org.uk
Telephone: 0303 123 1113
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Controlling Your Data

You can opt out of marketing communications, update your preferences, or withdraw consent at any time by contacting us via our website or email. Our contact details are available on our contact page.

We will not sell, distribute, or lease your personal data to third parties without your explicit consent or unless required by law. Sharing sensitive data will always require opt-in consent.

Retention Period

We retain your personal data only as long as necessary for the purposes outlined in this Policy or to comply with legal obligations. Typically, data is kept for a minimum of 6 months and a maximum of 5 years.

Third-Party Services

We may use trusted third-party service providers to assist in delivering our services. These providers are contractually obligated to process your data securely and in compliance with UK GDPR.

International Data Transfers

Some of our third-party service providers may store or process your personal data outside the UK. Where this happens, we ensure appropriate safeguards are in place in line with UK data protection law to protect your data to the same standard as if it were processed in the UK.

Cookies

Our website uses cookies to enhance user experience and analyse site traffic. You can manage cookie preferences through your browser settings. For more details, see our Cookie Policy.

If you have concerns about how your personal data is handled, please contact us. We are committed to addressing your queries promptly and transparently.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: Prepare, review and update a suitable care plan To communicate with you, your representatives and any appropriate external medical or health care professionals and suppliers about your individual needs and personalise the service delivered to you Manage payments, fees and charges Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) For the provision of health treatment
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey Service announcements	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To engage with you on our website, such as in the comments section of one of our blogs	(a) Identity (b) Contact	Necessary for our legitimate interests in communicating with you and enabling us to provide comments and assist with anything raised in your comments
To enable you to partake in a prize draw, competition or complete a survey, or receive an award for buying from us.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	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) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. This can be done by using a pixel or cookies which help to display relevant adverts on social media.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use our database and data analytics to improve our website, services, marketing, customer relationships and experiences.	(a) Technical (b) Usage (c) Contact (d) Identity (e) Marketing and Communications	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products and services and offers that may be of interest to you, such as in our direct marketing activities (including our email newsletter and social media marketing)	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our services and grow our business) or Consent
To gather CVs and other such information in respect of the recruitment process	(a) Identity (b) Contact	Fulfilment of contract Necessary for our legitimate interests (to grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We have also established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and 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, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us where you have opted to do so or where you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside Spa Therapy Limited for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out or unsubscribe links on any marketing message sent to you or by contacting us at any time.

We will need to maintain a restricted record of Contact and Identity Data where you have opted out of receiving marketing and this is to prevent any future marketing being carried out and, unless otherwise informed, no other processing shall be carried out in relation to this information.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy.

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.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

External Third Parties as set out in the Glossary.
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.

6. International transfers

We may use external third parties who are based outside the European Economic Area (EEA) and their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

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.

8. Data retention

How long will you use my personal data for?

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.

9. YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). 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 data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

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 continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Please note that if you ask us to delete any of your personal information which we believe is necessary for us to comply with our contractual or legal obligations, we may no longer be able to provide care and support services to you.

Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Where you object to direct marketing we shall maintain a restricted record of Contact and Identity Data recording that you have opted out of receiving marketing and we can ensure that no future marketing is carried out. Unless otherwise informed no other processing shall be carried out in relation to this restricted record. We will need to maintain where you have opted out of receiving marketing and this is to prevent any future marketing being carried out and, unless otherwise informed, no other processing shall be carried out in relation to this information.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. 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 at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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.

What we may need from you

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.

Time limit to respond

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.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

External medical and health care professionals and any individuals you have nominated as your representatives if required.
Service providers acting as processors based in the United Kingdom who provide IT and system administration services, payment processing services and data shredding services. Including Timely Ltd Salon & Spa Software.
Service providers that we engage to deliver goods you have ordered.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, credit reference agencies, marketing companies and insurers based in the United Kingdom who provide consultancy, marketing, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
Marketing automation platforms, acting as a processor, such as The Rocket Science Group LLC t/a MailChimp based in the US who provide email marketing automation services.
Survey development and distribution platforms, acting as a processor, such as Survey Monkey Inc. and SurveyMonkey Europe UC t/a SurveyMonkey, based in the US and within the EEA who provide online survey development services.
Social media platforms acting as processor or joint controllers