PRIVACY POLICY
This is the privacy notice of Lia Aesthetics- London Skin Clinic (‘we’, ‘our’, or ‘us’).
Our address is 11 Bear Street, Leicester Square, London, WC2 H7AS.
If you have any concerns about this notice or your privacy, please contact us.
Introduction
This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.
In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
Personal data we process
1. How we obtain personal data
The information we process about you includes information:
you have directly provided to us
we obtain as a result of monitoring how you use our website or our services
2. Types of personal data we collect directly
When you use our website or our services, for example, when you book an appointment through our website we ask you to provide personal data. This can be categorised into the following groups:
personal identifiers, such as your first and last names
contact information, such as your email address and your telephone number
medical information, such as whether you have suffered any adverse reactions to previous treatments
records of communication between us including messages sent through our website, email messages and telephone conversations
3. Types of personal data we collect from your use of our services
By using our website and our services, we process:
technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages
transaction information that includes the details of the appointments you have booked and payments made to us for those appointments
your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services
4. Our use of aggregated information
We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.
However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice.
5. Special personal data
Special personal data is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
We may collect special personal data about you if there is a lawful basis on which to do so.
For example, in order to provide you with some treatments we need to collect information about your health.
6. If you do not provide personal data we need
Where we need to collect personal data by law, or under 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 that contract.
In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category.
If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
7. Information we process because we have a contractual obligation with you
When you book an appointment, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal data.
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
8. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website you provide your consent to us to process information that may be personal data.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, we ask you to agree to our use of non-essential cookies when you access our website.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us. However, if you do so, you may not be able to use our website or our services further.
We aim to obtain and keep your consent to process your information. However, while we take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your personal data, provided that there is another basis on which we may do so. For example, we may have a legal obligation to do so.
9. Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
whether the same objective could be achieved through other means
whether processing (or not processing) might cause you harm
whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
improving our services
record-keeping for the proper and necessary administration of our business
responding to unsolicited communication from you to which we believe you would expect a response
exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property
insuring against or obtaining professional advice that is required to manage business risk
protecting your interests where we believe we have a duty to do so
10. Information we process because we have a legal obligation
Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal data.
How and when we process your personal data
11. Consultations
Your medical safety is important to us. A consultation aims to identify whether you have any contraindications that would suggest that our treatments are not suitable for you and that you are medically fit for treatment.
Before we treat you we ask you to complete a consultation form, on which we ask for medical information. We store this data with care and only for as long as necessary.
12. Booking an appointment
Booking is a strong indication of intention to enter into a contract with us. When you do so, we process your data under the basis of Contract.
When you book over the telephone or in-person, you do so with us directly. You provide us with this information.
When you book a treatment through our website, you do so through a third party application, FRESHA. The pages on their website may be branded consistently with our own, but we do not control them. FRESHA passes the necessary information to us.
More information about FRESHA can be found at https://www.fresha.com/privacy/
13. Payment information
Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.
At the point of payment, you are transferred to a secure page on the website of Stripe or another reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.
14. Photographs at the beginning and end of treatment
For insurance purposes we are required to take photographs of the treatment area before and after the treatment.
We do so on the basis that you have agreed under your contract with us.
We take additional care in processing photographs by using pseudonymisation, meaning that this information may no longer be attributed to a specific person without the use of additional information, which is stored securely and separately.
15. Service providers and business partners
We may share your personal data with businesses that provide services to us, or with business partners.
As examples:
we may pass your payment information to our payment service provider to take payments from you
we may use fraud prevention agencies and credit reference agencies to verify your identity and we may pass your information to those agencies if we strongly suspect fraud on our website
Use of information we collect through automated systems
16. Cookies
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.
They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.
They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.
Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.
The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.
This website is hosted by Vigbo, which uses cookies for a number of different reasons including for security purposes; for monitoring the performance of this website; and for providing a good experience for visitors. You can read more about how Vigbo uses cookies at https://support.vigbo. com/en/article/cookies-and-your-vigbo-site
17. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
Other matters
18. Your rights
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.
We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org
19. Data may be processed outside the UK
Our business is based in the UK.
Our website hosting provider, Vigbo, is based in Russia.
Your personal information may be stored through Vigbo’s data storage, databases and the general Vigbo applications. Data is stored on secure servers behind a firewall. Your data may be maintained, processed and stored by Vigbo and their authorised affiliates and service providers in the United States of America, in Europe (including in Lithuania, Germany and Ukraine), and in other jurisdictions as necessary for the proper delivery of their services and/or as may be required by law. Vigbo affiliates and service providers that store or process your data on Vigbo’s behalf are each contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their legal jurisdiction. Vigbo’s full privacy policy can be viewed at: https://www.vigbo.com/about/privacy
20. Control over your own information
It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes.
At any time, you may contact us to request that we provide you with the personal data we hold about you.
When we receive any request to access, edit or delete personal data we first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Please be aware that we are not obliged by law to provide you with all personal data we hold about you, and that if we do provide you with information, the law allows us to charge for such provision if doing so incurs costs for us. After receiving your request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
We remind you that we are not obliged by law to delete your personal data or to stop processing it simply because you do not consent to us doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which we may process it, we may do so on that basis. If we continue to process it, we shall tell you on which basis we do so.
21. Communicating with us
When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
22. Complaining
If you are not happy with our privacy policy, or if you have any complaint, then you should tell us.
When we receive a complaint, we record the information you have given to us on the basis of consent. We use that information to resolve your complaint.
If your complaint reasonably requires us to notify some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion whether we do give information, and if we do, what that information is.
If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal data, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.
23. Retention period
Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:
to provide you with the services you have requested
to comply with other law, including for the period demanded by our tax authorities
to support a claim or defence in court
24. Compliance with the law
Our privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’).
25. Review of this privacy policy
We shall update this privacy notice from time to time as necessary.