iBrowEnvy Privacy Policy

INTRODUCTION
Welcome to the iBrowEnvy privacy notice.
iBrowEnvy respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data, for example when you visit our websites (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
CONTENTS
  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HEALTH RELATED DATA
  4. HOW IS YOUR PERSONAL DATA COLLECTED
  5. HOW WE USE YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how iBrowEnvy collects and processes your personal data including any data you may provide through our websites or on the telephone, sign up for a cosmetic treatment, purchase a product or service or take part in a competition. Our websites are not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any other such notices, if any, and is not intended to override them.
CONTROLLER
iBrowEnvy is the controller and responsible for your personal data (collectively referred to as ” iBrowEnvy”, “we”, “us” or “our” in this privacy notice). We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights as a Data Subject under the Data Protection Legislation, please contact the DPO using the details set out below.
CONTACT DETAILS
Our full details are: You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues www.ico.org.uk . We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This privacy policy is dated 25th May 2018. Revisions and updates to our privacy policy may be made from time and time to enable us to protect your data and to comply with our legal obligations. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us
THIRD-PARTY LINKS
Our websites may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows: We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. EXCEPT AS SET OUT BELOW UNDER THE HEADING ‘HEALTH RELATED DATA’, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. HEALTH RELATED DATA
We provide treatment services to individuals such as treatments relating to skin, brows, and make up. Before we provide a treatment to an individual we request that the person who is to have the treatment either discloses information about certain types of medical and health related matters or confirms that there is no such information. We will retain this information in our records. We will obtain the express consent of the individual receiving a treatment to collect and retain this information and to use it in relation to the provision of the treatment and any aftercare or other matters arsing after the treatment. EXCEPT AS PROVIDED ABOVE, we will not disclose medical or health related information to any other person unless permitted to do so under the Data Protection Legislation. IF YOU FAIL TO PROVIDE PERSONAL DATA Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a contract to provide a product or service you have with us but we will notify you if this is the case at the time.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
We may receive personal data about you from various third parties and public sources as set out below:
  1. analytics providers including such as Google based inside and outside the EU;
  2. search information providers based inside or outside the EU;

5. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to including the Data Protection Legislation. Most commonly, we will use your personal data in the following circumstances: Click www.ico.org.uk to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we intend to rely on consent as the legal basis for processing your personal data, However, there may be other ways in which we may lawfully process your personal data where we do not have your consent and we will rely on these where appropriate other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time. Please contact us to do so.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we will primarily rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data relying on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity includes Type of data includes Lawful basis for processing including basis of legitimate interest includes
To register you as a new customer (a) Identity (b) Contact (c) Background Performance of a contract with you
To provide treatments (a) Identity (b) Contact (c) Health Related Performance of a contract with you
Necessary to comply with a legal obligation
To process and deliver your order for goods or services
(a) Manage payments, fees and charges (b) Collect and recover money owed to us
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications Performance of a contract with you
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Background Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications Performance of a contract with you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and its websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) Background Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about cosmetic treatments, goods or services that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile Necessary for our legitimate interests (to develop our products/services and grow our business)
MARKETING AND PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Background, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which cosmetic treatments, products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have given us consent or have requested information from us or purchased cosmetic treatments, goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by emailing us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a cosmetic treatment, product or service purchase, warranty registration, product or service experience or other transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose or we where we are permitted to use it under the Data Protection Legislation. If you want an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. INTERNATIONAL TRANSFERS
Some of our External Third Parties which provide services to us are based outside the European Economic Area (EEA) or have operations and service centres based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. The following are the main services in relation to which your personal data may be processed outside the EEA:
7.DATA SECURITY
We have put in place appropriate policies and security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8.DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may have to keep basic information about our customers (including Contact and Identity) as required or to enable us to comply with laws, regulations, and obligations imposed by local or national Governments. In some circumstances you can ask us to delete your data: see below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9.YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under the Data Protection Legislation in relation to your personal data. These rights include the right to: • Request access to your personal data. • Request correction of your personal data. • Request erasure of your personal data. • Object to processing of your personal data. • Request restriction of processing your personal data. • Request transfer of your personal data. • Right to withdraw consent. Please refer to the Glossary for more information about Your Legal Rights. If you wish to exercise any of the rights referred to above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10.GLOSSARY
DATA PROTECTION LEGISLATION
Data Protection Legislation means all applicable privacy and data protection laws including the General Data Protection Regulation ((EU) 2016/679) and any applicable national implementing laws, regulations and secondary legislation in England and Wales relating to the processing of Personal Data and the privacy of electronic communications, as amended, replaced or updated from time to time, including the Privacy and Electronic Communications Directive (2002/58/EC) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2003/2426).
EXTERNAL THIRD PARTIES
Service providers who provide various support services such as IT and system administration services including: 1. Google 2. PayPal 3. UK Bank data 4. Royal Mail, and other delivery service providers 5. Google Analytics 6. Google MY Business 7. Facebook Page
YOUR LEGAL RIGHTS
You have the right to: