Rookery Aesthetic Ltd
Privacy Policy and Cookie Policy
First created: 14.10.2018
Last reviewed: 28.10.2018
Last updated: 11.11.2018
Background:
Rookery Aesthetic Ltd understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site AND/OR You will be required to read and accept this Privacy Policy, when you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;]
“Our Site” means this website, https://rookeryaesthetic.com/;
“UK and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and]

“We/Us/Our” means Rookery Aesthetic Ltd , a limited company registered in England under 10478865, whose registered address is 3 Rookery Meadows, Scotter, DN213FD

“You/Your” means a data subject that has personal data that is to be processed or held by Rookery Aesthetic Ltd
“Candidate” means a data subject who is seeking employment
“Employer/Employee” Means a data subject who works for a registered business

2. Information About Us

  • Our Site, is owned and operated by Rookery Aesthetic Ltd, a limited company registered in England under 10478865, whose registered address is 3 Rookery Meadows, Scotter, DN213FD.
  • Our data protection officer is Andrew Balerdi who can be contacted at andrew@tgmc.co

3. Scope – What Does This Policy Cover?

  • This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. What Data Do We Collect?
Some data will be collected automatically by Our Site for further details, please see section 12 on Our use of Cookies other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for a job or if we are recruiting for candidates on your business’ behalf. Depending upon your use of Our Site, We may collect some or all of the following data:
Name
Contact details
Date of Birth
Gender
Act of kin
Emergency contact
Contact preferences – email/ SMS/ push notifications
Method of receiving appointment reminders
Medical information and records relating to the treatment being undertaken.
Purpose for which the personal data are intended to be processed:
The personal data collected from you will be used for the purposes of:
• facilitating, administering, and recording your current, and any future, treatment by us or third party practitioners, including General Practitioners and Consultants;
• to evaluate and improve the services provided by the clinic;
• being provided on an anonymised basis to Consentz to allow it to evaluate and improve its services; and
• providing you with information, from time to time, about the products and service we offer using the contact channels agreed by means of the contact preferences mentioned above.
• In addition, once they are provided, we will also retain (and process) your personal data to the extent necessary to enable us to establish, exercise or defend legal claims.

5. How Do We Use Your Data?

  •  All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
  • We use your data to provide the best possible services to you. This includes:
  • Providing and managing and up to date beauty and aesthetic service with a dedicated doctor and nurse team
  • Providing and managing your access to Our Site;
  • Personalising and tailoring your experience on Our Site;
  • Supplying up to date and relevant treatments for you;
  • Responding to communications from you;
  • Supplying you with email newsletters e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by clicking on the unsubscribe link at the bottom of every email;
  • Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
    • In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.
    • 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 telephone AND/OR text message AND/OR post with information, news and offers on job listings, candidates and potential employers. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
    • Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights or having an adverse effect on your personal data. We will only process your personal data if at least one of the following basis applies:
    1. you have given consent to the processing of your personal data for one or more specific purposes;
    2. processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
    3. processing is necessary for compliance with a legal obligation to which we are the subject;
    4. processing is necessary to protect the vital interests of you or of another natural person;
    5. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
    6. processing is necessary for the purposes of the legitimate interests pursued by us, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data. This would be in circumstances where jobs may be deemed relevant to a candidate or candidates would be a potential applicant for a potential employer.
    7. If you are a potential candidate looking for employment, We may hold or process your data and will foresee this action operating within your legitimate interests. We will ask for your permission and active consent to share your details, as listed in section 4, with potential employers. Should you no longer wish for your details to be shared in this way please let Us know or email rookeryaesthetic@gmail.com.
    • You are within your rights under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015 regulations to declare which personal details we share with potential employers. For example, only phone number and name or only name and email address.

6. How and Where Do We Store Your Data?

  • We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct a quarterly review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies and where we collect and store tour data are:
  • Filing cabinets – Some of your data, such as medical history may be stored on premises in locked filing cabinets. These can be accessed by Rookery Aesthetic staff only.
    • Staff computers – Every staff member has access to a computer and your data may be stored on these computers. Every computer is password protected.
    On each device data may be stored on a local hard drive, on saved temporary Outlook folders and in a contact database. Every computer is connected to a central network, where shared drives can be accessed by all staff. Your data will most likely be shared on this drive and be shared between staff members.
    • Staff mobile telephones – Contact information, such as name, job title will be stored on staff mobile phones. Staff will have access to stored data from their phones.

• Excel spreadsheets – We use spreadsheets to cross reference candidate data to make sure we manage the service more effectively.

Following 3rd Party locations.
• Consentz – is an online and app based medical clinic software. Your details are stored on servers based in the UK that are accessed by our staff. We will often process data from Consentz in order to facilitate the best service for you.
In general, access to your personal data will be restricted to those who have a need to access it in order to carry out their duties (for example, our medical staff and finance teams).
We will also share your personal data with the following external third parties in some circumstances:
• medical regulators such as the GMC, and government authorities such as HMRC or the police, if we are required to do so by law or if the regulator or authority requests it and we regard that request as reasonable;
• our insurers, legal advisers or other third parties who need access to it in the context of managing, investigating or defending claims or complaints; and
• Consentz Limited (a company registered in England and Wales under company number 08294329, whose registered office is at 5 Margaret Road, Romford, Essex, RM2 5SH) who provide us with this service by which your personal data are stored and processed.
• Your data will be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).AND
• Some or all of your data may be stored or transferred 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 or transfer 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 EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements. [If We intend at any time to transfer any of your data outside the EEA, We will always obtain your consent beforehand and we have put in place the following safeguards to protect your data:

And in order to administer these services we also consistently monitor via the cloud and notifies administrators when threats are detected, and components are disabled as well as missed scans and updates etc.
• Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
• Steps We take to secure and protect your data include:
• Identifying compromised hardware and this will be taken offline.
• Investigations of compromised hardware will be carried out to identify cause.
• We will determine scale of breach and detail what has been compromised, and how and by whom.
• We will then carry out relevant work to secure hardware.
• A full Report will be given to Rookery Aesthetic’s GDPR officer.
• You can expect a full report of your data that has been compromised within 3 working days.
o Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

• 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 information. 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.

Any numerical and statistical data such as this will be anonymised.
• In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

8. What Happens If Our Business Changes Hands?

  • We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.
  • 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.

9. How Can You Control Your Data?

When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (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 AND/OR by managing your Account email subscription preferences.

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.

10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it

  • 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 may restrict your internet browser’s use of Cookies. For more information, see section 12 and Our Cookie Policy https://Rookery Aesthetic.co.uk/privacy-policy/
  • You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible recruitment services to you.

11. How Can You Access Your Data?

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at rookery@aesthetic.com or using the contact details below in section 14.

12. What Cookies Do We Use and What For?

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve servive. For more details, please refer to section 5, above, and to section 12.6 below. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.

By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site to collate information on potential candidates or employers. For more details, please refer to section 5, above, and to section 12.6 below. These Cookies are not integral to the functioning of Our Site.

All Cookies used by and on Our Site are used in accordance with current English and EU Cookie Law.

Before Cookies are placed on your computer or device, subject to section 12.5 AND/OR section 12.8, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to block or allow cookies.

Certain features of Our Site depend on Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 12.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.10, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

The following first party Cookies may be placed on your computer or device. These are from Google and to opt out click here: https://tools.google.com/dlpage/gaoptout:

and the following third party Cookies may be placed on your computer or device:
• Our Site uses analytics services provided by Google, Facebook and Consentz. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
• The analytics service(s) used by Our Site use(s) Cookies to gather the required information. Certain of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 12.10.
• You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed.

In Chrome type the following in your address bar: chrome://settings/clearBrowserData and follow the instructions to delete, edit or change your permissions.
In Firefox go to about: preferences#privacy, the menus will then direct you where to go.
Follow these instructions from Microsoft for Internet Explorer and Microsoft Edge Browsers: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy.

For Safari follow these instructions from Apple: https://support.apple.com/kb/PH21411?locale=en_US
For further details, please consult the help menu in your internet browser or the documentation that came with your device.
• You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
• It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
OR

12. Summary of Your Rights under GDPR
Under the GDPR, you have:
• the right to request access to, deletion of or correction of, your personal data held by Us;
• the right to complain to a supervisory authority;
• be informed of what data processing is taking place;
• the right to restrict processing;
• the right to data portability;
• object to processing of your personal data;
• rights with respect to automated decision-making and profiling (see section 14 below).
To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in section 15 below.

14. Contacting Us
If you have any questions about Our Site or this Privacy Policy, please contact Us by email at rookeryaesthetic@gmail.com. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).

15. Changes to Our Privacy Policy
We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

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