GDPR Customer Privacy Notice
WHAT IS THE PURPOSE OF THIS DOCUMENT?
Guinot Mary Cohr (UK) Limited is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you prior to, during and after you engage our services at a Guinot salon, in accordance with the General Data Protection Regulation (GDPR).
1. Guinot Mary Cohr (UK) Limited is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
2. This notice applies to current and former customers of a Guinot salon. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.
3. It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.
4. DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the personal information we hold about you must be:
a) Used lawfully, fairly and in a transparent way.
b) Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
c) Relevant to the purposes we have told you about and limited only to those purposes.
d) Accurate and kept up to date.
e) Kept only as long as necessary for the purposes we have told you about.
f) Kept securely.
5. THE KIND OF INFORMATION WE HOLD ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation.
5.1. We will collect, store, and use the following categories of personal information about you:
• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
• Date of birth.
• Visit history, including dates and details of treatments arranged or undertaken at a Guinot salon.
• Next of kin/guardian and emergency contact information.
• Spouse/recommended client details such as name and title.
5.2. We may also collect, store and use the following “special categories” of more sensitive personal information:
• Information about your health, including any medical condition or allergy you may suffer from.
6. HOW IS YOUR PERSONAL INFORMATION COLLECTED?
6.1. We collect personal information about our customers via the following methods:
· our client record card
· data capture form
· during any telephone call directly with you/contact us section of the website/email, in which case the information is input directly into our electronic system/contact us section of the website/email which you fill out.
6.2 We may collect additional personal information in the course of providing services to you in a Guinot salon related to our products and services you receive throughout the period of you using our services.
7. HOW WE WILL USE INFORMATION ABOUT YOU
7.1. We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
a) Where we need to perform the contract we have entered into with you to provide our products and or services.
b) Where we need to comply with a legal obligation.
c) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
7.2. We may also use your personal information in the following situations, which are likely to be rare:
a) Where we need to protect your interests (or someone else’s interests).
b) Where it is needed in the public interest or for official purposes.
7.3.Situations in which we will use your personal information
7.3.1. We need all the categories of information in the list above (see paragraph 5 ) primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below:
• Providing our products and or services under the contract we have entered into with you.
• Complying with health and safety obligations.
• To prevent fraud.
• To conduct data analytics studies to review and better understand customer needs.
7.3.2. Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
7.4.If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you/provide you with our products and or services, or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our customers).
7.5.Change of purpose
7.5.1. We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
7.5.2. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
8. HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
8.1. ”Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:
a) In limited circumstances, with your explicit written consent.
b) b) Where it is needed in the public interest, such as for equal opportunities monitoring.
d) 8.2. Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Do we need your consent?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
9. AUTOMATED DECISION-MAKING
9.1. Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
9.2. We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
10. DATA SHARING
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