Harborne Spa & Clinic understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.harbornespaandclinic.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
In this Policy, the following terms shall have the following meanings:
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means Harborne Spa & Clinic [, a limited company registered in England under company number 11298567, whose registered address is 8 South Street, Harborne, B17 0DB and whose main trading address is also 8 South Street, Harborne, B17 0DB.
2.1 Our Site is [owned and] operated by Harborne Spa & Clinic [, a limited company registered in England under company number 11298567, whose registered address is 8 South Street, Harborne, Birmingham, B17 0DB and whose main trading address is also 8 South Street, Harborne, Birmingham, B17 0DB
2.2 We are not VAT registered
2.3 [Our Data Protection Officer is <<insert name>>, and can be contacted by email at <<insert email address>>, by telephone on <<insert telephone number>>, or by post at <<insert address>>.]
2.4 [We are regulated by <<insert name(s) of regulator(s)>>.]
2.5 [We are a member of <<insert name(s) of association(s) etc.>>.]
2.6 [<<insert further information as required>>.]
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
Depending upon your use of Our Site, We may collect some or all of the following personal [and non-personal] data:
5.2 [date of birth;]
5.4 [business/company name]
5.5 [job title;]
5.7 [contact information such as email addresses and telephone numbers;]
5.8 [demographic information such as post code, preferences, and interests;]
5.9 [financial information such as credit / debit card numbers;]
5.10 [IP address;]
5.11 [web browser type and version;]
5.12 [operating system;]
5.13 [a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;]
5.14 [<<add further information as required>>.]
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the [Data Protection Act 1998] OR [GDPR] at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 [Supplying Our
6.2.2 [Personalising and tailoring Our
6.2.3 [Replying to emails from you;]
6.2.4 [Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by <<insert description of opt-out method>>);]
6.2.5 [Market research;]
6.2.6 [<<add further uses as required>>.]
6.3 [With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by [email] AND/OR
AND/OR [text message] AND/OR [post] with information, news, and offers on Our
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.5.1 <<insert description of how long each type of personal data will be retained, or how its retention will be determined if this is not a fixed period>>;
6.5.2 <<Add further items as required>>.
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 [Your data will only be stored in the UK.]
7.2 [Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).]
7.2 [Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
7.2.1 <<describe measures in place>>.]
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 Steps We take to secure and protect your data include:
7.4.1 <<insert details (list where appropriate)>>.
8.1 [Subject to section 8.2, We will not share any of your data with any third parties for any purposes.
8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.]
8.1 [[We may share your data with other companies in Our group [for <<insert description of purpose(s)>>]. This includes [Our subsidiaries] AND/OR [Our holding company and its subsidiaries].]
8.2 [We may sometimes contract with third parties to supply
8.3 [We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.]
8.4 [The third party data processors used by Us and listed below are located] OR [We may sometimes use third party data processors that are located] outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the [Data Protection Act 1998] OR [GDPR] including:
8.4.1 [<<identify third party>>.] <<describe measures in place>>;
8.4.2 <<add further items as required>>.]
8.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.]
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your 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).
10.2 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.
You may access certain areas of Our Site without providing any 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 have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details using the contact details below in section 13.