Updated: 18 October 2018
Introduction
This is the privacy policy of Rodrigues Relaxation. In this policy, “we”, “our”, or “us” refer to Rodrigues Relaxation.
This privacy policy sets out how, why and for how long we process information that we collect from our users (“you”), or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on.
We take seriously the protection of your privacy and maintaining the security of any personal information received from you. We understand that you are entitled to know that your personal data will not be used for any purpose unintended by you.
We strictly adhere to the requirements of data protection legislation in the UK, including that required by the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org or at ico.org.uk/for-the-public/is-my-information-being-handled-correctly.
By using our website you acknowledge that you have read and agree to the terms and conditions of this privacy policy. If you do not agree to all of the terms of this privacy policy, your sole and exclusive remedy is to discontinue use of the website.
How, why and for how long we process your personal data
Except as set out below, we do not share, sell or disclose to a third party any information collected through our website, unless disclosure is necessary to (1) conform to legal requirements, (2) enforce the Rodrigues Relaxation Terms of Use or protect our rights, or (3) protect your vital interests or the vital interests of another person.
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category. If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data. If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
Usage data
When you browse our website, we process data about your use of the website. This may include your approximate 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 website visits. This data is non-personally identifiable and so you are anonymous to us. The legal basis for processing this data is our legitimate interests, namely monitoring, analysing and improving our website usage and the services we provide. This data is stored in our Analytics service, Google Analytics, for an indefinite period of time, or until we decide we no longer need it for the purposes outlined above.
You can prevent your data from being used by Google Analytics by installing the Google Analytics opt-out browser add-on.
When you book a treatment through our website
When you book a treatment through our website we process your name, telephone number and email address. We may use this data to:
- verify your identity for security purposes
- communicate with you about your booking and treatment
We process this information on the basis that there is a contract between us, or that you have requested we use the information before we enter into a legal contract. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
When you fill out a consultation form before your first treatment
When you fill out a consultation form, we process your name, address, telephone number, email address, date of birth, occupation and a medical/lifestyle history. We may use this data to provide you with a safe, effective and appropriate treatment.
We process this information on the basis that there is a contract between us, or that you have requested we use the information before we enter into a legal contract. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
Under the GDPR, medical and some lifestyle data falls under the definition of “special category data”. As such, we are required to state the condition under which we process this data in addition to the lawful basis stated above. We process your medical/lifestyle data under the condition that it is necessary for the purposes of the provision of health care/treatment.
When you make an enquiry through our contact form or by sending us an email
When you submit an enquiry, we process the information contained in your enquiry, including your name and email address. We believe that you would reasonably expect us to process this data for the purposes of responding to your enquiry, and so we process it on the basis that there is a legitimate interest to you and to us in doing so.
We process this data and any data in subsequent email communication between you and us for as long as is necessary to adequately deal with your enquiry and track our communications with you.
When you subscribe to a newsletter
When you sign up to receive a newsletter, we ask for your consent to process your personal information. We process this information in order to send you the information you have subscribed to. We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. You can withdraw your consent at any time by instructing us by email at privacy@rodriguesrelaxation.co.uk or by clicking the Unsubscribe link in the newsletter you receive.
When you sign up for a newsletter, we may store your personal information in the Mailchimp email marketing platform instead of in our own database. You can read the Mailchimp privacy policy here.
Information provided by you on the understanding that it will be shared with a third party
Our website allows you to post information with a view to that information being read, copied, downloaded or used by other people. Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
Here are the individual cases where you may post information with a view to that information being read, copied, downloaded or used by other people:
- When you post a comment on an article
When you post a comment on an article, we process the information you submit in the form. By checking the Consent checkbox on the comment form, you agree to the name you provide being published along with your comment on our website. We process your email address for the legitimate interest of preventing spam and therefore damage to the reputation of Rodrigues Relaxation. Apart from this, we do not specifically use any of the information you provide except to allow it to be displayed or shared.As well as being stored in our database, your name, email address, the content of your comment and your IP address may be processed on Automattic’s servers for the legitimate interest of preventing comment spam and therefore damage to the reputation of Rodrigues Relaxation. You can read Automattic’s privacy policy here.
We store the information you provide until such time as it is no longer relevant to be displayed on the website or, in the case of personal information in article comments, until you withdraw your consent. You can withdraw this consent at any time by instructing us by email at privacy@rodriguesrelaxation.co.uk. For all other information submitted, provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete information that you have posted or to make it anonymous. You can make a request by contacting us at privacy@rodriguesrelaxation.co.uk.
When you make a payment for a product or service
When you make a payment on our website, payment information is never taken by us. At the point of payment, you are transferred to a secure page on the website of PayPal, our payment service provider. Your payment is controlled by Paypal, not by us. You can find information about Paypal’s privacy policies and practices here.
When you book our chauffeur service
When you book our chauffeur service, we may share your telephone number with our chauffeur. We believe that you would reasonably expect us to share this information for the purposes of providing you with this service, and so we process it on the basis that there is a legitimate interest to you and to us in doing so.
Information we process because we have a legal obligation
We may process any of your data identified in this policy in order to comply with a legal obligation, or in order to protect your vital interests or the vital interests of another natural person. This may include your personal information.
Other information we may process
We may process any of your 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.
We may process any of your data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
Accessing, updating and removing your personal information
You can at any time request a copy of your personal data processed by us, or request to have it updated if it is incorrect. You can do both these things by sending an email to privacy@rodriguesrelaxation.co.uk. After receiving your request, we will tell you when we expect to provide you with the information requested or correct the incorrect information.
If you wish to remove your personal information from our website, you can make a request by sending an email to privacy@rodriguesrelaxation.co.uk.
Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Complaints regarding content on our website
We moderate user generated content when necessary, but we are not always able to do so as soon as that content is published.
If you complain about any of the content on our website, we shall investigate your complaint. If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgement as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we may not correspond with you about it.
Processing of your data outside the European Union
We use outsourced services in countries outside the European Union in certain aspects of our business. Accordingly data obtained within the European Union could be processed outside the European Union.
We use Mailchimp and Automattic for the purposes as outlined in this policy. These services are situated in the USA. The European Commission has made an “adequacy decision” with respect to the data protection laws of the USA, by means of the Privacy Shield Framework. Transfers to the USA will therefore be protected by appropriate safeguards adopted or approved by the European Commission. You can obtain a copy of the EU-US Privacy Shield Framework here.
Our use of cookies
About cookies
Cookies are small text files that are placed on your device by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another. Cookies allow us to distinguish you from other visitors to the website, helping us to provide you with a good user experience and allowing us to improve the site.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date. A session cookie will expire at the end of the user session, when the web browser is closed.
You can choose to disallow cookies by changing your browser settings. However, by doing so, you may hinder your user experience on this and other websites. You can read more about cookies and how to disallow them at www.allaboutcookies.org.
Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.
Cookies that we use
Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
How you can complain
If you are not happy with our privacy policy or if have any complaint then you can tell us by sending an email to privacy@rodriguesrelaxation.co.uk.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/.
Retention period for personal data
Except as otherwise mentioned in this privacy policy, we keep your personal information only for as long as required by us:
- to provide you with the services you have requested
- to comply with other law, including for the period demanded by our tax authorities
- to support a claim or defence in court
Third party websites
We may include links to third party websites that are controlled and maintained by others. It is your responsibility to review the privacy and cookie policies of these sites. We are not responsible for the policies and practices of third party sites.
More information and review of this privacy policy
You can find more information about UK data protection legislation at the Information Commissioner’s website.
We may update this privacy policy from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website.
If you have any questions about this privacy policy please contact us by email at privacy@rodriguesrelaxation.co.uk or through our contact form.