Zen Skin Clinic Limited (“We”, “Us”, “Our”) Privacy Statement.
This is Our Privacy Statement which details how We use your personal data (“Personal Data”) when you use Our Websites www.zenskinclinic.co.uk. We take Our data protection responsibilities seriously and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Purpose of This Privacy Notice
This privacy notice aims to give you information on how Zen Skin Clinic Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a service or take part in a competition. This website is 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 the other notices and is not intended to override them.

Changes To The Privacy Notice And Your Duty To Inform Us Of Changes
This version was last updated on May 1, 2018 and historic versions can be obtained by contacting us. Please note, We may change this Privacy Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our website, you’re agreeing to be bound by this Policy.
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.
Any questions regarding this Privacy Policy and our privacy practices should be sent by writing to Zen Skin Clinic Ltd, 92 West End Lane, NW6 2LU, London, UK with note “Privacy Policy”.

Third-Party Links
This website may include links to third-party websites, plug-ins and applications. 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 policies. When you leave our website, we encourage you to read the privacy policy notice of every website you visit.

Who We Are?
Zen Skin Clinic is a Laser Aesthetics Clinic based in London, UK. We are a limited company with registered number 11338204 . The address registered is Zen Skin Clinic Ltd, Flat 4, 44 Fellows Road, NW3 3LH, London, UK.

How do we collect information from you?
We use different methods to collect data from and about you including through:
 • Direct interactions. You may give us your Identity, personal data and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
 • apply for our products or services;
 • create an account on our website;
 • subscribe to our service or publications;
 • request marketing to be sent to you;
 • enter a competition, promotion or survey; or
 • give us some feedback.
 • call us to for consultation purposes

Automated technologies or interactions
As you interact with our website, we automatically collect non-personal Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

What Type of Data We Collect From 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:
 • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
 • Contact Data includes billing address, delivery address, email address and telephone numbers.
 • Financial Data includes bank account and payment card details.
 • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
 • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
 • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
 • Usage Data includes information about how you use our website, products and services.
 • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
 • Treatment Data includes information about the treatment you wish to receive from us. This information could include 'health data' which is a special category of personal data and therefore requires us to take extra steps to ensure it is adequately protected.

We collect, use and share Aggregated Data such as statistical or demographic data for marketing purposes. 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.
With the exception of Treatment Data, we do not collect any other 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.

Zen Skin Clinic website logs IP addresses and browser types to provide you with the best possible user experience and allow us insight into consumer behaviour. You can browse our site without entering any personal information, and therefore remain anonymous during your visit.

How We Use Your Personal Data
We will only use your personal data when the law allows it. Most commonly, we will use your personal data in the following circumstances:
 • Where we need to perform the contract we are about to enter into or have entered into with you.
Mainly:
 • Process a payment you have made, either over the phone or in clinic.
 • Seek your views or comments on the service we provide.
 • Process, book and confirm appointments that you have requested.
 • Send you requested product or service information.
 • Notify you of changes to our service.
 • Process a job application.
 • Send you communication via your chosen route of newsletters and campaigns which you have requested and may be of interest.
 • Process Reward Points and notify you of your rewards via your chosen method.
 • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
 • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data 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 by contacting us.
We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations. We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.

How We Use Your Health Data
In light of the services which we provide to our customers, it will often be necessary for us to use information about your health. Even in the broadest sense of the word, 'health' information is a special category of personal data which requires us to have an additional lawful basis for using this information. Where we use information about your health for the purpose of providing our services to you (or in preparation for us to provide services to you), the additional lawful basis on which we shall rely will be that such use is necessary in order for us to provide you with health care or treatment.

Lawful Basis for Using Your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact Us 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 information below.

Purpose/Activity
To register you as a new customer
Type of data
(a) Identity
(b) Contact
Lawful basis for processing including basis of legitimate interest
Performance of a contract with you

Purpose/Activity
To process and deliver our services to you including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
Type of data
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(f) Health information
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(c) Necessary for us to provide health care or treatment

Purpose/Activity
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(e) Health information
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
(d) Necessary for us to provide health care or treatment

Purpose/Activity
To enable you to partake in a prize draw, competition or complete a survey
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

Purpose/Activity
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data
(a) Identity
(b) Contact
(c) Technical
Lawful basis for processing including basis of legitimate interest
(a) 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)
(b) Necessary to comply with a legal obligation

Purpose/Activity
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Lawful basis for processing including basis of legitimate interest
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)

Purpose/Activity
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data
(a) Technical
(b) Usage
Lawful basis for processing including basis of legitimate interest
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)

Purpose/Activity
To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to develop our products/services and grow our business)


Who has access to your information
We promise never to sell or rent your information to third parties for marketing or any other purposes. Your data is safe with us.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional Offers
We may use your Identity, Contact, 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 products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased good 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.

Information Our Website Gathers/Tracks
First and third party cookies are used to provide information and offer improvements to optimise quality of adverts served. You can change the cookie management settings in your web browser to stop these adverts. If you are a registered Facebook or Instagram user, you may receive targeted adverts from Zen Skin Clinic. You can read about how Facebook works by following this link https://en-gb.facebook.com/policies/cookies/ or https://help.instagram.com/155833707900388

Use of ‘cookies’
Like many other websites, Zen Skin Clinic website uses cookies. 'Cookies' are small pieces of information sent by an organisation to your computer, or any similar device you use to access the internet e.g. smart phone, tablet or other mobile device and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. This helps us to improve our website and deliver a better more personalised service.
It is possible to switch off cookies by setting your browser preferences. Turning off cookies may result in a loss of functionality when using our website.
A number of cookies used by our website last only for the duration of your web session and they will expire when you close your browser.

More Information on cookies: http://www.google.co.uk/intl/en/analytics/privacyoverview.html

Security Precautions In Place To Protect The Loss, Misuse Or Alteration Of Your Information
When you give us personal information, we take steps to ensure that it’s treated securely. Any sensitive information is encrypted and protected.
Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

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. If you wish to get 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.

Disclosures Of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in the table below. Such third parties consist of:
 • IT: Service providers acting as processors who provide IT and system administration services.
• Advisors: Professional advisers including lawyers, bankers, auditors and insurers who provide related services.
 • Authorities: HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
We may also share your personal information as required by law or to respond to a government request, or in connection with a corporate change.
We will not provide your details to any other third party with your prior consent.

International Transfers
We do not transfer your personal data outside the European Economic Area (EEA).

Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
 • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out 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 20 working days. 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.

Privacy Policy