BACKGROUND:
Our MD Center Limited trading as Our Skin Clinic understands that your privacy is
important to you and that you care about how your personal data is used. We respect
and value the privacy of everyone who visits this website, www.ourskinclinic.uk/
www.ourskinclinic.com
(“Our Site”) and will only collect and use personal data in ways that are described
here, and in a way that is consistent with our obligations and your rights under the
law.
Please read this Privacy Policy carefully and ensure that you understand it.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Cookie” means a small text file placed on your computer
or device by Our Site when you visit certain parts
of Our Site and/or when you use certain features
of Our Site. Details of the Cookies used by Our
Site are set out in Part 14, below; and
“Cookie Law” means the relevant parts of the Privacy and
Electronic Communications (EC Directive)
Regulations 2003 as amended;
2. Information About Us
Our Site is owned and operated by Our MD Center Limited trading as Our Skin Clinic
company number 13808951 whose registered office is at Unit L 19 Cellini Road Nine
Elms Point London SW8 2FQ
Main trading address: 12 Gateway Mews Bounds Green London N11 2UT.
Data Protection Representative: Suzelly Farias Email address: [email protected]
Telephone number: 0204 547 6067
3. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain
links to other websites. Please note that we have no control over how your
data is collected, stored, or used by other websites and we advise you to
check the privacy policies of any such websites before providing any data to
them.
4. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018
(collectively, “the Data Protection Legislation”) as ‘any information relating to
an identifiable person who can be directly or indirectly identified in particular by
reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you
to be identified. Personal data covers obvious information such as your name
and contact details, but it also covers less obvious information such as
identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we
will always work to uphold:
a) The right to be informed about our collection and use of your personal
data. This Privacy Policy should tell you everything you need to know,
but you can always contact us to find out more or to ask any questions
using the details in Part 15.
b) The right to access the personal data we hold about you. Part 13 will tell
you how to do this.
c) The right to have your personal data rectified if any of your personal
data held by us is inaccurate or incomplete. Please contact us using the
details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise
dispose of any of your personal data that we hold. Please contact us
using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular
purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on
your consent as the legal basis for using your personal data, you are
free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided
personal data to us directly, we are using it with your consent or for the
performance of a contract, and that data is processed using automated
means, you can ask us for a copy of that personal data to re-use with
another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not
use your personal data in this way.
For more information about our use of your personal data or exercising your
rights as outlined above, please contact us using the details provided in Part
15.
It is important that your personal data is kept accurate and up-to-date. If any of
the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the
Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you
have the right to lodge a complaint with the Information Commissioner’s
Office. We would welcome the opportunity to resolve your concerns ourselves,
however, so please contact us first, using the details in Part 15.
6. What Data Do You Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of
the personal data set out in the table below, using the methods also set out in
the table. Please also see Part 14 for more information about our use of
Cookies and similar technologies and Cookie Policy. We do not collect any
‘special category’ or ‘sensitive’ personal data or personal data relating to
children or data relating to criminal convictions and/or offences.
Data Collected
Identity Information including name; title;
date of birth; gender.
Contact information including postal
address; residence address; phone &
mobile; email
Business information including business
name; job title; profession; nature of
business; place of business; contact
information.
Payment information including card
details; bank information;
Profile information including preferences;
interests; purchase history; login details;
Technical information including IP
address; browser type; browser version;
operating system.
Data from third parties including
technical information; contact
information; profile information.
How We Collect the Data
Through our website using the online
contact page; online subscription/login
form; email post or over the telephone.
Through our website using the online
contact page; online subscription/login
form; email post or over the telephone.
Through our website using the online
contact page; online subscription/login
form; email post or over the telephone.
Through our website using the online
contact page; online subscription/login
form; email post or over the telephone.
Through our website using the online
contact page; online subscription/login
form; email post or over the telephone.
Through our website using the online
contact page; online subscription/login
form; email post or over the telephone.
Through our website using the online
contact page; online subscription/login
form; email post or over the telephone.
7. How Do You Use My Personal Data? Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
What We Do
Accessing Our Site and
contacting Us.
Providing and managing
your Account with Us,
registering you, booking
calls.
Providing and managing
your access to Our Site.
Personalising and tailoring
your experience on Our
Site.
Administering Our Site.
Administering our
business.
Supplying our services to
you.
Managing payments for
our services.
Personalising and tailoring
our services for you.
Communicating with you.
Supplying you with
information by email
AND/OR post that you
have opted-in-to (you may
opt-out at any time by
email or telephone.)
What Data We Use
Contact; Identity; enquiry;
Business.
Identity; Contact;
Business; Payment;
Technical; 3rd Party Data,
includes 3rd parties.
Identity; Contact;
Business; Payment;
Technical; 3rd Party Data,
includes 3rd parties.
Identity; Contact;
Business; Payment;
Technical; 3rd Party Data,
includes 3rd parties
Identity; Contact;
Business; Payment;
Technical; 3rd Party Data
includes 3rd parties.
Identity; Contact;
Business; Payment;
Technical; 3rd Party Data,
includes 3rd parties.
Identity; Contact;
Business; Payment;
Technical; 3rd Party Data;
providing our services,
includes 3rd parties.
Identity; Contact;
Business; Payment;
Technical; 3rd Party Data,
includes 3rd parties.
Identity; Contact;
Business; Payment;
Technical; 3rd Party Data,
includes 3rd parties.
Identity; Contact;
Business; Payment;
Technical; 3rd Party Data,
includes 3rd parties.
Identity; Contact;
Business; Payment;
Technical; 3rd Party Data;
offers; news; marketing,
includes 3rd parties.
Our Lawful Basis
Legitimate interest; We
have a commercial
interest in using your data
to deal with your enquiry.
Consent. You give positive
consent when applying to
open the account with Us
and use the website and
receive Our services.
Consent. You give positive
consent when applying to
open the account for
services and use the
website.
Consent. You give positive
consent when applying to
open the account for
services and use the
website.
Legitimate interest; We
have a commercial
interest in using your data
to administer Our Site.
Legitimate interest; We
have a commercial
interest in using your data
to administer Our Site.
Contract. We cannot fulfil
the provisions of Our
Services to you unless we
use your Data.
Contract. By contracting to
take Our services you
agree to our using Data
for these purposes.
Consent. You consent to
our use of Data to provide
you with a personalised
service and which you will
then enter into a contract
to purchase.
Consent.
Consent.
With your permission and/or where permitted by law, we may also use your
personal data for marketing purposes, which may include contacting you by
email telephone, text message or post with information, news, and offers on
our products or services. You will not be sent any unlawful marketing or spam.
We will always work to fully protect your rights and comply with our obligations
under the UK Data Protection Legislation and the Privacy and Electronic
Communications Regulations 2003 as amended and you will always have the
opportunity to opt-out. We will always obtain your express opt-in consent
before sharing your personal data with third parties for marketing purposes
and you will be able to opt-out at any time.
Third Parties (including any whose details appear on our site,) and whose
content appears on Our Site may use third-party Cookies, as detailed below in
Part 14. Please refer to Part 14 for more information on controlling cookies.
Please note that we do not control the activities of such third parties, nor the
data that they collect and use themselves, and we advise you to check the
privacy policies of any such third parties.
We may use automated systems for carrying out certain kinds of decisionmaking or profiling.
If at any point you wish to query any action that wetake on
the basis of this or wish to request ‘human intervention’ (i.e. have someone
review the action themselves, rather than relying only on the automated
method), the Data Protection Legislation gives you the right to do so. Please
contact us to find out more using the details in Part 15.
We will only use your personal data for the purpose(s) for which it was
originally collected unless we reasonably believe that another purpose is
compatible with that or those original purpose(s) and need to use your
personal data for that purpose. If we do use your personal data in this way and
you wish us to explain how the new purpose is compatible with the original,
please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or
incompatible with, the purpose(s) for which it was originally collected, wewill
inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process
your personal data without your knowledge or consent. This will only be done
within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of
the reason(s) for which it was first collected. We are required by law to retain
records for certain purposes such as HMRC and tax for at least 6 years.
Accordingly we will keep Data for 6 years at most and thereafter it will be
deleted.
9. How and Where Do You Store or Transfer My Personal Data?
We will store some of your personal data in the UK. This means that it will be
fully protected under the Data Protection Legislation.
Some of your personal data may be stored within the European Economic
Area (the “EEA”). The EEA consists of all EU member states, plus Norway,
Iceland, and Liechtenstein. This means that your personal data will be fully
protected under the EU GDPR and/or to equivalent standards by law.
Transfers of personal data to the EEA from the UK are permitted without
additional safeguards.
We may store some or all of your personal data in countries outside of the UK.
These are known as “third countries”. We will take additional steps in order to
ensure that your personal data is treated just as safely and securely as it
would be within the UK and under the Data Protection Legislation as follows:
In all cases We will only store or transfer personal data in or to countries that
are deemed to provide an adequate level of protection for personal data. For
further information about adequacy decisions and adequacy regulations,
please refer to the Information Commissioner’s Office.
The security of your personal data is essential to us, and to protect your data,
we take a number of important measures, including the following:
limiting access to your personal data to those employees, agents,
contractors, and other third parties with a legitimate need to know and
ensuring that they are subject to duties of confidentiality;
Procedures for dealing with data breaches (the accidental or unlawful
destruction, loss, alteration, purposes, subject to the following exceptions.
If we sell, transfer, or merge parts of our business or assets, your personal
data may be transferred to a third party. Any new owner of our business may
continue to use your personal data in the same way(s) that we have used it, as
specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain
personal data, which might include yours, if we are involved in legal
proceedings or complying with legal obligations, a court order, or the
instructions of a government authority.
10. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes,
subject to the following exceptions.
If we sell, transfer, or merge parts of our business or assets, your personal
data may be transferred to a third party. Any new owner of our business may
continue to use your personal data in the same way(s) that we have used it, as
specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain
personal data, which might include yours, if we are involved in legal
proceedings or complying with legal obligations, a court order, or the
instructions of a government authority.
11. How Can I Control My Personal Data?
11.1 In addition to your rights under the Data Protection Legislation, set out
in Part 5, when you submit personal data via Our Site, you may be
given options to restrict our use of your personal data. In particular, we
aim to give you strong controls on our use of your data for direct
marketing purposes (including the ability to opt-out of receiving emails
from us which you may do by unsubscribing using the links provided in
our emails and at the point of providing your details and by managing
your Account).
11.2 You may also wish to sign up to one or more of the preference services
operating in the UK: The Telephone Preference Service (“the TPS”), the
Corporate Telephone Preference Service (“the CTPS”), and the Mailing
Preference Service (“the MPS”). These may help to prevent you
receiving unsolicited marketing. Please note, however, that these
services will not prevent you from receiving marketing communications
that you have consented to receiving.
12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data
at all. However, to use all features and functions available on Our Site you
may be required to submit or allow for the collection of certain data.
You may restrict our use of Cookies. For more information, see Part 14 and
our Cookie Policy.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for
details of that personal data and for a copy of it (where any such personal data
is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or
postal addresses shown in Part 15. To make this as easy as possible for you,
a Subject Access Request Form is available for you to use. You do not have to
use this form, but it is the easiest way to tell us everything we need to know to
respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request
is ‘manifestly unfounded or excessive’
(for example, if you make repetitive requests) a fee may be charged to cover
our administrative costs in responding.
We will respond to your subject access request within 10 days and, in any
case, not more than one month of receiving it. Normally, we aim to provide a
complete response, including a copy of your personal data within that time. In
some cases, however, particularly if your request is more complex, more time
may be required up to a maximum of three months from the date we receive
your request. You will be kept fully informed of our progress.
14. How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or
device. First-party Cookies are those placed directly by us and are used only
by us. We use Cookies to facilitate and improve your experience of Our Site
and to provide and improve our services. We have carefully chosen these
Cookies and have taken steps to ensure that your privacy and personal data is
protected and respected at all times.
By using Our Site, you may also receive certain third-party Cookies on your
computer or device. Third-party Cookies are those placed by websites,
services, and/or parties other than us. Third-party Cookies are used on Our
Site for example if we chose to use third party payment services. For more
details, please refer to Our Cookie Policy here. These Cookies are not integral
to the functioning of Our Site and your use and experience of Our Site will not
be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current
Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a
suitable form of prompt or pop up requesting your consent to set those
Cookies. By giving your consent to the placing of Cookies you are enabling us
to provide the best possible experience and service to you. You may, if you
wish, deny consent to the placing of Cookies; however certain features of Our
Site may not function fully or as intended.
Certain features of Our Site depend on Cookies to function. Cookie Law
deems these Cookies to be “strictly necessary”. Your consent will not be
sought to place these Cookies, but it is still important that you are aware of
them. You may still block these Cookies by changing your internet browser’s
settings as detailed below, but please be aware that Our Site may not work
properly if you do so. We have taken great care to ensure that your privacy is
not at risk by allowing them.
In addition to the controls that we provide, you can choose to enable or disable
Cookies in your internet browser. Most internet browsers also enable you to
choose whether you wish to disable all Cookies or only third-party Cookies. By
default, most internet browsers accept Cookies, but this can be changed. For
further details, please consult the help menu in your internet browser or the
documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time,
however you may lose any information that enables you to access
Our Site more quickly and efficiently including, but not limited to, login and
personalisation settings.
It is recommended that you keep your internet browser and operating system
up-to-date and that you consult the help and guidance provided by the
developer of your internet browser and manufacturer of your computer or
device if you are unsure about adjusting your privacy settings.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data
protection, including to make a subject access request, please use the
following details (for the attention of Suzelly Farias):
Email address: [email protected]
Telephone number: 0204 547 6067
Postal Address: Unit L 19 Cellini Road Nine Elms Point London SW8 2FQ
16. Changes to this Privacy Policy
We may change this Privacy Notice from time to time. This may be necessary,
for example, if the law changes, or if we change our business in a way that
affects personal data protection.
Any changes will be immediately posted on Our Site and you will be deemed
to have accepted the terms of the Privacy Policy on your first use of Our Site
following the alterations. We recommend that you check this page regularly to
keep up-to-date. This Privacy Policy was last updated January 2022.