Privacy Policy

 

  1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site http://www.essentialvitality.co.uk/ including any information you may provide through our site when you purchase a product or service, sign up to our newsletter or take part in a prize draw or competition; and through the information you provide us prior to receiving a massage treatment or service. It also explains how and why we collect sensitive personal data when you complete a health questionnaire or answer questions prior to receiving our services.

By providing us with your data, you warrant to us that you are over 13 years of age.

I, Paola Saunders am the data controller and am responsible for your personal data (referred to as “I” and “me” in this privacy notice).

Contact Details

Our full details are:

Full name of legal entity: Paola Saunders trading as Essential Vitality

Email address: psaunders@essentialvitality.co.uk

Postal address: 151 Brox Road, Ottershaw, Surrey, KT16 0LG

If you are not happy with any aspect of how I collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I should be grateful if you would contact me first if you do have a complaint so that I can try to resolve it for you.

It is very important that the information I hold about you is accurate and up to date. Please let me know if at any time your personal information changes by emailing me at psaunders@essentialvitality.co.uk

  1. WHAT DATA WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process certain types of personal data about you as follows:

  • Identity Data may include your first name, last name, username, marital status, title, date of birth and gender.
  • Contact Data may include your home or workplace address, email address and telephone numbers.
  • Financial Data may include your bank account details for payment of invoices where applicable.
  • Transaction Data may include details about payments made between us via Bank Transfer, Paypal or Stripe.
  • Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
  • Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
  • Usage Data may include information about how you use our website, products and services.
  • Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
  • We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

Sensitive Data

We need to collect sensitive data about you in order to provide

  • Corporate On-Site Massage Services, to include Seated Acupressure Massage Services – also referred to as On-Site Massage, Chair Massage, and any additional Massage and/or Beauty Therapy or Complementary Therapies as part of Essential Vitality’s services
  • Display Screen Equipment (DSE) Assessments
  • Health and Wellbeing advice in the Workplace

SENSITIVE DATA WE REQUIRE

We require your explicit consent for processing sensitive data, so when you submit your details on our Health Questionnaire and in communicating with the qualified Massage Therapist or DSE Assessor, we will request consent from you to process the sensitive information which you disclose to Essential Vitality.

Where we are required to collect personal data by law, or under the terms of the contract between us and if you do not wish provide us with that data when requested, we may not be able to perform the contract (for example, provide the massage services or DSE Assessment). If you don’t provide us with the requested data, we may have to cancel or modify our services and we will notify you at the time.

We need to collect the following sensitive data, on a Health Questionnaire, about you in order to carry out our massage services, and to ensure that the massage is safe for you to receive:

  • Recent past and present health conditions, if any
  • Details of any current medical treatment
  • Medication currently receiving
  • Major surgery, hospitalisation or illness – past or present
  • Details of specific medical conditions relevant to the massage services we provide
  • Lifestyle habits (eg. exercise, smoking, alcohol)

If you would like a copy of the Health Questionnaire before completing it prior to receiving a massage please contact psaunders@essentialvitality.co.uk. Telephone: 07768 131017.

All sensitive personal data will be treated with the strictest confidence at all times and will only be shared with another therapist (other than the therapist who was present when the Health Questionnaire was first completed or the therapist who received the Health Questionnaire at the first appointment, prior to providing the first massage or treatment) when he/she is to provide the massage service to an individual by way of continuing a treatment or service (ie the therapist needs to have access to past and present medical information recorded on the Health Questionnaire and the previous massage treatments provided by another therapist to ensure safety of the individual continuity of service.

 HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:

Direct interactions: You may provide data by filling in forms manually or on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:

  1. order our products or services
  2. enquire about or products or services
  3. create an account for on-line bookings
  4. subscribe to our service or publications
  5. request resources or marketing be sent to you
  6. enter a competition, prize draw, promotion or survey; or
  7. give us feedback or testimonials
  8. complete an application form for contract work

Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies.

Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources for more information please contact psaunders@essentialvitality.co.uk

4.  HOW WE USE YOUR PERSONAL DATA

  • We will only use your personal data when legally permitted. The most common uses of your personal data are:
  •  Where we need to perform the contract between us.
  • 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 ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at psaunders@essentialvitality.co.uk

Purposes for processing your personal data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant. 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 email us at psaunders@essentialvitality.co.uk 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

 

Type of data

 

Lawful basis for processing

 

To register you as a new customer

 

(a) Identity

(b) Contact

 

Performance of a contract with you

 

To process and deliver your order of our services including:

(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

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests to recover debts owed to us

 

To provide our services to you

 

(a) Identity

(b) Contact

(d) Transaction

 

(a) Performance of a contract with you

(b) Necessary for legitimate interests

(c) Necessary to comply with a legal obligation

 

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

 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 

(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

 

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

 

(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

 

To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(a) Identity

(b) Contact

(c) Technical

 

(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

 

To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

 

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 site updated and relevant, to develop our business and to inform our marketing strategy

 

To make suggestions and recommendations to you about 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 communications  You will receive marketing communications from us if you have:

  1. requested information from us or purchased goods or services from us; or
  2. if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
  3. in each case, you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.You can ask us or third parties to stop sending you marketing messages at any time by emailing us at psaunders@essentialvitality.co.uk or by unsubscribing to the marketing emails.Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/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. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at psaunders@essentialvitality.co.uk If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.We may process your personal data without your knowledge or consent where this is required or permitted by law.

5.  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 in paragraph 4 above:

  1.  Service providers who provide IT and system administration services.
  2. Professional contractual workers appointed to carry out administrative duties on behalf of Essential Vitality
  3. Professional therapists contracted to carry out work on behalf of Essential Vitality.
  4. Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  5. HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

6.  INTERNATIONAL TRANSFERS  We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please email us at psaunders@essentialvitality.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.  DATA SECURITY  We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

8.  DATA RETENTION  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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. With specific regard to Health Questionnaires and Record Keeping on a client/therapist basis we will keep both personal and sensitive data, confidentially and securely, for at least 7 years, in accordance with professional guidelines, practices and legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

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 data protection laws in relation to your personal data. These 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.https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

  1. 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.
  2. 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.
  3. 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.
  4. If you wish to exercise any of the rights set out above, please email us at psaunders@essentialvitality.co.uk

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 statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. COOKIES

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 statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.