Privacy Notice

BACKGROUND:

Richard Ward Associated Ltd 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 all of our customers 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.

1. Information About Us

Richard Ward Associates Ltd.

Limited company registered in England under company number 2747059.

Registered address: 1st Floor, 47-57 Marylebone Lane, London W1U 2NT.

Main trading address: 82 Duke of York Square, London SW3 4LY.

VAT number: 563179426.

Data Protection Officer: Julie Norman.

Email address: [email protected]

Telephone number: 020 7730 1222.

Postal address: 82 Duke of York Square, London SW3 4LY.

 

2. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

 

3. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “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.

The personal data that we use is set out in Part 5, below.

 

4. 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 Notice 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 11.

b) The right to access the personal data we hold about you. Part 10 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 11 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 11 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 11.

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 11.

 

5. What Personal Data Do You Collect and How?

We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table.

 

Data Collected	How We Collect the Data
Identity Information including name, title, date of birth, gender.	Directly from the customer, by telephone or online form, or in person at the Salon.
Contact information including address, email address, telephone number.	Directly from the customer, by telephone or online form, or in person at the Salon.
Special Category (Health) specific to receiving treatments & services. (Depending on the particular service(s) we are providing, we may be required to ask questions related to your medical history. We will obtain your consent prior to storing information related to your medical history. Examples of medical data may include allergies, pregnancy or an injury that may impact our service.)	Directly from the customer, by telephone or online form, or in person at the Salon.
Payment information including card details.	Directly from the customer, by telephone or online form, or in person at the Salon.
Profile information including preferences and purchase history. (We also store notes with respect to services we undertake to ensure we maintain and exceed our level of service; for example, your preferred hair style, colour formula codes, how you like your coffee and who your preferred members of staff are.)	Directly from the customer, by telephone or online form, or in person at the Salon.
CCTV Video Footage.	Recorded in a DVR and stored on site
Client Visual/Image Records.	By taking photographs, with consent of the data subject.

 

6. 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	What Data We Use	Our Lawful Basis
Administering our business	Identity Contact Payment Information Profile Information Special Category (Health)	Contract   Legitimate Interest   In relation to special category information, consent
Supplying our products and services to you	Identity Contact Payment Information Profile Information Special Category (Health) Client Visual/Image Records	Contract
Managing payments for our products services	Payment Information	Contract
Personalising and tailoring our products services for you	Identity Contact Profile Information Special Category (Health) Client Visual/Image Records	Consent   Legitimate Interest
Communicating with you	Identity Contact Profile Information	Contract   Legitimate Interest
Supplying you with information by email or text message that you have opted-in-to (you may opt-out at any time by following the unsubscribe link in the email, or calling the reception team)	Identity Contact Profile Information	Consent   Legitimate Interest
Sending you appointment reminders (As a standard business procedure, we will contact you via phone, email or SMS to confirm appointments booked and remind you of upcoming appointments. We consider your having made the appointment as consent to undertake this activity, but you may opt-out at any time by contacting the salon on 0207 730 1222 or emailing your request to [email protected])	Contact Information	Consent   Legitimate Interest
Security monitoring / video surveillance	CCTV Footage	Legitimate Interest
We may use visual images on our website & social media channels	Client Visual/Image Records	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 and post with information, news, and offers on our products and 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 Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out

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 11.

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, we will 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.

 

7. 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. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

 

Type of Data	How Long We Keep It
Identity Information including name, title, date of birth, gender.	6 years following the date of the last salon visit.
Contact information including address, email address, telephone number.	6 years following the date of the last salon visit.
Special Category (Health) specific to receiving treatments & services.	6 years following the date of the last salon visit.
Payment information including card details.	Payment information is deleted immediately after processing.
Profile information including preferences and purchase history.	6 years following the date of the last salon visit.
CCTV Video Footage.	30 days.
Client Visual/Image Records.	6 years following the date of the last salon visit, or if the image has been posted online with the data subjects’ consent, it will remain for as long as the Company is operational unless the data subject requests removal.

 

8. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.

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, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

 

9. 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.

 

10. 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 11. 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 28 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.

 

11. 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 Julie Norman):

Email address: [email protected]          .

Telephone number: 020 7730 1222.

Postal Address: 82 Duke of York Square, London SW3 4LY.

 

12.  How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

 

13. Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement

 

14. Changes to this Privacy Notice

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 made available on our website, https://www.richardward.com/privacy-policy/. This Privacy Notice was last updated on 17^th April 2020.