Shwe Tan Privacy Notice

Introduction

The following privacy notice outlines how Shwe Tan collects, uses, protects, and transfers your personal data.

This privacy policy covers Shwe Tan Limited.
("Shwe"/ "Shwe Beauty/ Shwe Tan") 42 High Street, Old Harlow, Essex, CM17 0DW
This is our registered office.

Shwe Tan provides services including Sun Beds, Spray Tans, Waxing, Threading, Manicures, Pedicures, Callus Peels, Gel Nails, Dermalogica Facials, Tinting, Massage, and Lashes.

The data protection officer/data owner for the organisation is Sarah Aherne. You can contact the data protection officer/data owner by sending an email to info@shwetan.co.uk or writing to Shwe Tan, 42 High Street, , Old Harlow, Essex, CM17 0DW.

Personal data collected

The personal data that we collect is:

• Name
• Home address
• Email address
• Date of Birth
• Phone number
• Health information

Purpose and Legal Basis for Processing Your Data

Shwe Tan takes your privacy seriously and we will never sell or rent your personal data to any third-party. Sharing of your data and direct marketing activities are only carried out with your express consent, which you are free to withdraw at any time.

We need to obtain and process your personal data to provide you with our products, services, and treatments and to fulfill our business and legal obligations. We will never collect any personal information from you that we do not need or retain any data that is no longer necessary for the purposes specified in this notice.

Where we request sensitive personal data from you (i.e. health or medical data), the reason(s) for the request will be clearly given along with the purposes of the processing. Explicit consent through a signature will always be required for us to obtain and process your health information.

Who is processing my data?

Shwe Tan, 42 High Street, Old Harlow, Essex, CM17 0DW are the data controller and processes your personal information for the purposes laid out in this privacy notice. Phorest, Anglesea Mills, 9 Anglesea Row, Smithfield, Dublin 7, D07 W5NE, Ireland, acts as a data processor on behalf of Shwe Tan and have access to personal information only in cases that customer support or troubleshooting is required by Shwe Tan. Further, they must process the personal information in accordance with this Privacy Notice and as permitted by applicable data protection laws.

Your personal data is processed to:

• Collect specific personal data (name, address, email, contact number, DOB) that is required to enter into a contract to sell a product or service.
• Engage in communication with you including confirmation and reminders of appointments, and requests to cancel or change bookings.
• Collect Health information to perform the agreed services appropriately, and potentially highlight areas where products and services may cause issues to clients because of their health.
• Ensure a safe service and provide industry-standard advice.
• Select relevant offers, promotions, and information for you.
• Estimate the number of customers we have.
• Hold personal data that is required by law or to respond to legal process.
• Hold for insurance purposes.
• Store customer records.

Your rights as the individual

If your personal data is held by Shwe Tan you hold particular rights over it. Where you have provided consent for us to contact you as part of our marketing services, you have the right to modify or withdraw your consent at any time by using the unsubscribe option accompanied by all of our direct marketing or by contacting the Shwe Tan Data Officer.

You also have the right:

• To be informed of how your personal data will be used before it is collected.
• To access your personal data and to information on how your information is used after it has been gathered.
• To have personal data corrected if it is incomplete, inaccurate or out-of-date.
• To request the removal or deletion of personal data where there is no compelling reason for its continued processing.
• To restrict processing, to 'block' processing of your personal data.
• To data portability, having your data moved, copied or transferred from Shwe Tan to another organisation in an easily readable format.
• To object to direct marketing from us.

Special categories of personal data collected

Health questions are asked in many of our consent forms to potentially highlight treatments that may have a negative effect on your health due to medication you are taking or a condition you have. Shwe Tan asks for consent prior to gathering and processing this information. At any time after giving consent, you can withdraw you consent, subject to legal, insurance and contractual restrictions (see more on 'your rights as an individual'). Your privacy is very important to us and we only use this information for determining your suitability for the treatment.

Process of collection

Your personal data is collected when you provide it to us through Phorest software, our website, over the phone, in Shwe Tan salons, by email, social media, in writing or any other means by which you provide it to us. Information is stored using the Phorest software platform as well as some level of paper record keeping.

Shwe Tan gives you access to information about your account and bookings through Phorest software, for the limited purpose of viewing and updating that information.

Children's Privacy

Shwe Tan does not collect the personal data of children under the age of 13 without parental or guardian consent. If you believe that we hold any information from or about a child under age 13, please contact Shwe Tan and if we cannot immediately obtain appropriate parental or guardian consent, will remove the personal data from storage.

Data Sharing

Your personal data is shared only with Phorest representatives in cases that customer support and troubleshooting is required for the salon. Shwe Tan do not share your personal information with any third-party without your prior consent, other than those already disclosed in this privacy notice or as part of our legal obligations under the relevant data protection laws.

Use of Data Processors

Data processors are third parties who provide some elements of our business services for us. Where we use a third-party, we have strict agreements in place governing the processing of your personal data, on which no action can be taken without instruction from us. The third-parties with whom we work will never share or disclose your personal information and will hold it securely at all times.

Phorest

Shwe Tan uses software provided by Phorest to manage the salon appointments. In doing so, personal details (name, address, phone number, email) and specific health/treatment information is stored for the purpose of providing the service and managing the booking.

Here is a link to their Privacy Notice. https://www.phorest.com/privacy-notice

How Long Do We Keep Your Data?

Shwe Tan retains your personal data for as long as necessary to provide you with our services as our client. Shwe Tan is required under tax laws to keep your personal data for a minimum of 7 years. Health and Safety records will be retained for 10 years and where we have your consent for marketing purposes, we will retain the minimum required data until you notify us that you no longer wish to receive such information.

The criteria for which we would continue to process your personal information include:

• Where there is a legal basis, obligation or legitimate interest to continuing processing your personal information
• Where processing is necessary for the establishment, exercise or defense of legal claims

Transfers of personal information

When your personal data is processed through Phorest software, all of it is held within the EU. Your information is processed by the Phorest software and stored in the Amazon Web Services cloud. During this process, your data is encrypted in transit and at rest.

Consequences of not providing your personal information to Shwe Tan

In the event that you want to purchase a product or service from Shwe Tan, certain personal information is required to enter into a contract with you. Shwe Tan will not be able to enter into a contract with you to fulfill an attempt to purchase a product or service if you do not provide your personal information. As noted in this privacy statement, we are processing your personal data to comply with legal and statutory obligations and in the performance of a contract. You can always choose not to provide personal information; however, we will be unable to provide certain products, services, and treatments in these instances.

Safeguarding your Personal Data

Appropriate measures are taken to protect your personal data from access from unauthorized persons or inappropriate access, internal or external. Your connection to the Phorest system uses a HTTP Secure communication protocol and TLS security. This means all information passed to the Phorest system is encrypted during data input and transfer to the cloud. Any paper files recording your personal data are held in a locked filing cabinet or safe which can only be accessed by authorised personnel in the salon. Employees are only assigned specific access rights and can only access the salon software with the PIN number assigned to them by the management of the salon.

Your Privacy using our Website

Our website Privacy policy is effective from August 2009.

The below information sets out how Shwe Tan uses and protects any information that you give Shwe Tan when you use our website.

Shwe Tan is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

Shwe Tan may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Complaints

In the occurrence that you want to make a complaint about how your personal data was gathered, how it is being processed by Shwe Tan (or third parties used by Shwe Tan or you are not satisfied with how a complaint has been handled, you retain the right to lodge a complaint directly with the supervisory authority and [insert salon name] and also the Shwe Tan Data Protection Officer/ GDPR Owner.

Data Protection Commissioner, Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
+44 (0) 303 123 1113

Shwe Tan Data Protection Officer/GDPR Owner
42 High Street, Old Harlow, Essex, CM17 0DW.