1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other
words, where we determine the purposes and means of the processing of that personal data.
1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether
you would like to receive direct marketing communications and limit the publication of your information.
1.5 In this policy, “we”, “us” and “our” refer to RJO Massage Therapy. For more information about us, see Section 12.
2. DATA PROTECTION OFFICER
2.1 Our data protection officer’s contact details are: Debbie Richards, RJO Massage Therapy, 87 Church Road, Newport, NP19 7EH. firstname.lastname@example.org - 01633 479029.
3. HOW WE USE YOUR PERSONAL DATA
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location,
browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about
the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed
for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring
and improving our website and services.
3.3 We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address,
telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment
details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for
this processing is the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.
3.4 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be
processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
3.5 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our
website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction
data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal
basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract
and our legitimate interests, namely our interest in the proper administration of our website and business.
3.6 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”).
The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this
processing is consent.
3.7 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims,
whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests,
namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.8 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal
data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests
or the vital interests of another natural person.
3.9 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
4. PROVIDING YOUR PERSONAL DATA TO OTHERS
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its
subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or
maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether
in court proceedings or in an administrative or out-of-court procedure.
4.3 Financial transactions relating to our website and services are handled by our payment services providers, Stripe. We will share transaction data
with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing
with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies
and practices at https://stripe.com/gb/privacy.
4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is
necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of
another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of
legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. RETAINING AND DELETING PERSONAL DATA
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations
in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a)Name and Email Address will be retained for a minimum period of 1 month following form submission, and for a maximum period of 6 months following
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will
determine the period of retention based on the following criteria:
(a)the period of retention of Name and Email Address will be determined based on your enquiry type.
5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with
a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7. YOUR RIGHTS
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details
have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation
of these rights.
7.2 Your principal rights under data protection law are:
(a)the right to access;
(b)the right to rectification;
(c)the right to erasure;
(d)the right to restrict processing;
(e)the right to object to processing;
(f)the right to data portability;
(g)the right to complain to a supervisory authority; and
(h)the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with
certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data
concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of
your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any
incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data
are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based
processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes;
and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where
processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the
establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of
the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you
require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification
of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise
process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural
or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that
the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in
the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make
such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing
which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes).
If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on
grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public
7.10 To the extent that the legal basis for our processing of your personal data is:
(b)that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering
into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and
machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with
a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or
the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at
any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us.