Privacy Policy - FUL

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Introduction

The Company is committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information. We are committed to protecting your privacy by ensuring that any personal data is collected and used lawfully and transparently.

Collecting Personal Information

The type and frequency of any personal data collected will always depend on how our website and services are used. If you do not wish to provide us with certain categories of personal data, you may not be able to use our services in their entirety.

We may collect, store and use the following kinds of personal information:
a) information that you provide to us when registering with our website (including your email address);
b) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
c) information contained in or relating to any communications that you send to us or send through our website;
d) information contained in purchase requests, click and collect requests and online purchases;
e) information you enter in our online chat function;
f) information collected and needed as part of your appointment or service;
g) we may also collect additional data from you as part of our recruitment process, during your employment or when you visit our office via CCTV;
h) any other personal information that you choose to send to us

We may receive information about you from specific third parties such as business partners, sub-contractors, advertising networks, analytics providers, hosting providers and search information providers.

When you visit our website, a record of your device’s IP address is retained which is used anonymously in order to determine website and page visitors. For more information on how we use online identifiers or cookies please visit our cookies policy.

Our Legal Basis For Processing

Before processing any personal data, we ensure that at least one lawful basis under GDPR is met.

We will not disclose personal data for any purpose other than what the data was originally collected for; unless there is an overriding legal basis that enables this processing.

We may collect, hold, use and disclose the information collected to compile statistical data and to maintain our database; to develop or improve our website; respond to any queries; notify you of any upcoming marketing, training or other events that we think may be of interest to you; provide you with publications; manage quality control and compliance issues; manage systems administration; provide you or your organization with advice; notify you about important changes or developments to our services; contact you for your views on our services or to determine the suitability for employment.

Personal information submitted to us will be used for the purposes specified in this policy or on the relevant pages of the website.

We may use your personal information to:
a) administer our website and business;
b) enable your use of the services available on our website or in our salons/shops;
c) send you non-marketing commercial communications;
d) send you email notifications that you have specifically requested;
e) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
f) send you marketing communications relating to our business which we think may be of interest to you by email or similar technology (you can inform us at any time if you no longer require marketing communications);
g) to perform our services under our contract with you – we process information in order to support and maintain our existing or potential contractual relationships under the lawful basis ‘performance of a contract’. We may process personal data in order to provide various supporting client services, take payments and to make improvements to our website;
h) for fraud prevention – we have a “legitimate interest” to process data, including credit card details, in order to prevent fraud;
i) to defend legal issues – we have a “legitimate interest” to process data which may assist us in connection with the establishment, exercise or defence of legal claims;
j) to ensure compliance with health and safety and insurance obligations – we have a “legitimate interest” to process data which will assist us in our compliance with health and safety standards and obligations and our insurance obligations;
k) when you apply for a vacancy – you provide several pieces of data to us directly during the recruitment exercise. In some cases, and to facilitate our “legitimate interest” we will collect data about you from third parties, such as employment agencies and former employers when gathering references or credit reference agencies. Should you be successful in your job application, we will gather further information from you, for example. your bank details and next of kin details, once your employment begins. We have a Legal Obligation to ensure you have a right to work in the UK and make reasonable adjustments for you if you have a disability. The ongoing lawful basis we reply on to process your data will be under our legal obligations or legitimate interests;
l) for marketing purposes.

We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party direct marketing.

Data Retention

We will only keep your data for as long as necessary, unless there is an overriding legal ground. We will not retain data if it is deemed unlawful to do so. Data may be held for purposes relating to the establishment, exercise or defence of legal claims which the group or our clients may face. We will also typically keep data concerning your account for at least seven years from the date you end your contract with us. Some data may be deleted before this time period depending on the category of that data in line with our commercial legitimate interests and retention schedule, for example, data provided to us in the course of an unsuccessful job application will be retained no longer than 6 months after the recruitment exercise.

Disclosing Personal Information

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:
a) to the extent that we are required to do so by law;
b) in connection with any ongoing or prospective legal proceedings;
c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling.

Except as provided in this policy, we will not provide your personal information to third parties.

SECURITY AND YOUR PERSONAL INFORMATION

We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

Amendments

We may update this policy from time to time.

Your Rights

You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

We may withhold personal information that you request to the extent permitted by law.

You may instruct us at any time not to process your personal information for marketing purposes.

In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

Updating Information

Please let us know if the personal information that we hold about you needs to be corrected or updated.

Klarna

In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice.