Updated: 25th May 2018
1. Introduction
This is our privacy policy. It tells you how we collect and process data received from you on our site. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. If you have any comments on this privacy policy, please email them to info@luxwax.co.uk.
2. Who We Are
Here are the details that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) says we have to give you as a ‘data controller’:
- Our site address is luxwax.co.uk.
- Our company name is LuxWax Ltd.
- Our registered address is 73 Tottenham Lane, London, N8 9BE.
- Our nominated representative or Data Protection Officer is Mrs Gail Castagnetti and they can be contacted at info@luxwax.co.uk.
3. What kind of personal data we may collect
Customers:
In order to provide the best possible service to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you.
Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below:
- Name
- Birth date
- Sex/gender
- Photograph
- Marital status
- Contact details
- Emergency contacts
- Health conditions
- Keep records of products used during treatment
- Keep records of treatments carried out
- Please note that the above list of categories of personal data we may collect is not exhaustive.
Suppliers:
Usually all we require is contact details of relevant individuals who have expressed an interest in the services that we provide and that the supplier has obtained appropriate consent for their details to be shared with us.
Website Users:
We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide.
Prospective Employees:
In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you.Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to enable us to offer you employment opportunities which are relevant to you. In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions:
- Name
- Date of Birth
- Photograph
- Marital status
- Contact details
- Education details
- Employment history
- Emergency contacts and details of any dependents
- Referee details
- Immigration status (whether you need a work permit)
- Nationality/citizenship/place of birth
- A copy of your driving licence and/or passport/identity card
- National Insurance number
- Details of any criminal convictions if this is required for a role that you are interested in applying for;
- Details about your current remuneration, pensions and benefits arrangements;
- Information on your interests and needs regarding future employment
- Extra information that you choose to tell us
- Extra information that your referees chooses to tell us about you
- Extra information that our Clients may tell us about you, or that we find from other third-party sources such as job sites
- *Please note that the above list of categories of personal data we may collect is not exhaustive.
Other Users, such as Referees and Emergency Contacts:
In order to provide Candidates and Staff with suitable employment opportunities, we require some basic background information (such as name, email address and telephone number). We only ask for very basic contact details, so that we can get in touch with you either for a reference or because you’ve been listed as an emergency contact for one of our Candidates or Staff members.
We may collect and process the following data about you:
- Information you put into forms or surveys on our site at any time
- A record of any correspondence between us
- Details of transactions you carry out through our site
- Details of your visits to our site and the resources you use
- Information about your computer (e.g. your IP address, browser, operating system, etc.) for system administration and to report aggregate information to our advertisers. Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
- you have given consent to the processing of your personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is necessary to protect the vital interests of you or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
4. Cookies
All cookies used on our site are set by us.
Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can prevent the setting of cookies by adjusting the settings on your browser. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of the site.
Our cookies will be used for:
Essential session management
- creating a specific log-in session for a user of the site in order that the site remembers that a user is logged in and that their page requests are delivered in an effective, secure and consistent manner;
- recognising when a user of the site has visited before allowing us to identify the number of unique users we receive to the site and make sure we have enough capacity for the number of users that we get;
- recognising if a visitor to the site is registered with us in any way;
- we may also log information from your computer including the existence of cookies, your IP address and information about your browser program in order to allow us to diagnose problems, administer and track your usage of our site.
Functionality
- customising elements of the promotional layout and/or content of the pages of the site.
Performance and measurement
- collecting statistical information about how our users use the site so that we can improve the site and learn which parts are most popular to users.
5. How we use what we collect
We use information about you to:
- Present site content effectively to you.
- Provide information, products and services that you request, or (with your consent) which we think may interest you.
- Carry out our contracts with you.
- Allow you to use our interactive services if you want to.
- Tell you our charges.
- Tell you about other goods and services that might interest you. We will also let other people do this, and we (or they) may contact you.
If you are already our customer, we will only contact you electronically about things similar to what was previously sold to you.
If you are a new customer, you will only be contacted if you agree to it.
If you don’t want to be contacted for marketing purposes, please tick the relevant box that you will find on screen.
Please note: We don’t identify individuals to our advertisers, but we do give them aggregate information to help them reach their target audience, and we may use information we have collected to display advertisements to that audience.
In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section in 5, you can let us know at any time by contacting us at info@luxwax.co.uk, and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible products and services to you.
In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you if you don’t provide your personal data in these cases.
6. Where we store your data
We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfil your order and deal with payment.
By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.
Payment will be encrypted. If we give you a password, you must keep it confidential. Please don’t share it. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts.
We only keep your personal data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it. In any event, we will conduct an [annual] review to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.
7. Disclosing your information
We are allowed to disclose your information in the following cases:
- If we want to sell our business, or our company, we can disclose it to the potential buyer.
- We can disclose it to other businesses in our group.
- We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
- We can exchange information with others to protect against fraud or credit risks.
We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. These are the third parties that have access to your information:
Clover by Natwest
Stripe
ABT Insurance
Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.
8. Your rights
You can ask us not to use your data for marketing. You can do this by ticking the relevant boxes on our forms, or by contacting us at any time at info@luxwax.co.uk.
Under the GDPR, you have the right to:
- request access to, deletion of or correction of, your personal data held by us at no cost to you;
- request that your personal data be transferred to another person (data portability);
- be informed of what data processing is taking place;
- restrict processing;
- to object to processing of your personal data; and
- complain to a supervisory authority.
You also have rights with respect to automated decision-making and profiling as set out in section 11 below.
To enforce any of the foregoing rights or if you have any other questions about our site or this Privacy Policy, please contact us at info@luxwax.co.uk.
9. Links to other sites
Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our site. 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.
10. Changes
If we change our Privacy Policy, we will post the changes on this page. If we decide to, we may also email you.
11. Automated Decision-Making and Profiling
- In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
- The right described in section 11.1 does not apply in the following circumstances:
- the decision is necessary for the entry into, or performance of, a contract between the you and us;
- the decision is authorised by law; or
- you have given you explicit consent.
- Where we use your personal data for profiling purposes, the following shall apply:
- Clear information explaining the profiling will be provided, including its significance and the likely consequences;
- Appropriate mathematical or statistical procedures will be used;
- Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
- All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
12. Dispute Resolution
- The Parties will use their best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy Policy or any breach of it.
- If any such dispute cannot be settled amicably through ordinary negotiations between the parties, or either or both is or are unwilling to engage in this process, either party may propose to the other in writing that structured negotiations be entered into with the assistance of a fully accredited mediator before resorting to litigation.
- If the parties are unable to agree upon a mediator, or if the mediator agreed upon is unable or unwilling to act and an alternative mediator cannot be agreed, any party may within 14 days of the date of knowledge of either event apply to LawBite to appoint a mediator under the LawBite Mediation Procedure.
- Within 14 days of the appointment of the mediator (either by mutual agreement of the parties or by LawBite in accordance with their mediation procedure), the parties will meet with the mediator to agree the procedure to be adopted for the mediation, unless otherwise agreed between the parties and the mediator.
- All negotiations connected with the relevant dispute(s) will be conducted in confidence and without prejudice to the rights of the parties in any further proceedings.
- If the parties agree on a resolution of the dispute at mediation, the agreement shall be reduced to writing and, once signed by the duly authorised representatives of both parties, shall be final and binding on them.
- If the parties fail to resolve the dispute(s) within 60 days (or such longer term as may be agreed between the parties) of the mediator being appointed, or if either party withdraws from the mediation procedure, then either party may exercise any right to seek a remedy through arbitration by an arbitrator to be appointed by LawBite under the Rules of the LawBite Arbitration Scheme.
- Any dispute shall not affect the parties’ ongoing obligations under this Privacy Policy.