Privacy and Cookies Policy

Introduction
1. We are committed to safeguarding the privacy of our website visitors and customers; in this policy, we explain how we will handle your data.
2. This policy applies where we are acting as a data controller concerning your personal and medical data; in other words, where we determine the purposes and means of the processing of that personal data.
3. Our website incorporates privacy controls which affect how we will process your data. By using the privacy controls, you can manage the communications you receive from us and the data relating to you that we keep. You can access the privacy controls via https://casafia.com/profile.
4. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
5. In this policy, “we”, “us” and “our” refer to Casafia Medical Aesthetics Limited. For more information about us, see Section 19.
The personal data that we collect
1. In this Section 2 we have set out the general categories of personal data that we process.
2. We may process data enabling us to get in touch with you (“contact data”). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you.<!– If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider. –>
3. We may process your website user account data (“account data”). The account data may include your name, email address, account creation and modification dates, website settings and marketing preferences.The primary source of the account data is you.
4. We may process information relating to our customer relationships (“customer relationship data”). The customer relationship data may include your name your contact details, your history with us as a client, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you. The source of the customer relationship data is you.
5. We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
6. We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data”). The communication data may include the communication. Our website will generate the metadata associated with communications made using the website contact forms.
7. We 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.
8. We may process data relating to your medical history and relevant to future treatments (“clinical data”). The source of the clinical data is you.
Purposes of processing and legal bases
1. In Section 3, we have set out the purposes for which we may process personal data and the legal basis of the processing.
2. Operations – We may process your personal data for the purposes of operating our website, processing and fulfilling orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation and credit control. The legal basis for this processing is our legitimate interests, namely the proper and safe administration of our services, business and website.
3. Publications – We retain the right to publish and distribute data left on our website as part of your product or service review. This we may publish on our website or social media. Such testimonials will consist of: an excerpt from your review, your first name and, potentially the treatment or product that you have reviewed. We may share this content across social media. In an instance where such a review may use a recognisable image of you, we shall always seek permission first. Without written permission, no recognisable content will be published. We reserve the right to republish or share posts from you on social media that pertain to us. With the exception of the above, no other data pertaining to you will be published by us.
4. Relationships and communications – We may process contact data, account data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
5. Personalisation – We may process account data and/or usage data for the purposes of personalising the content you see on our website. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
6. Direct marketing – We may process contact data, account data, customer relationship data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS or post and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely [promoting our business and communicating marketing messages and offers to our website visitors and service users.
7. Research and analysis – We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
8. Record keeping – We may process your personal data `nd transactional data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
9. Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
10. Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely [the proper protection of our business against risks.
11. Legal claims – We may process your personal data 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.
12. Legal compliance and vital interests – We may also process 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.
Automated decision-making
1. We will not use your data for the purposes of automated decision-making.
Providing your personal data to others
1. Casafia Medical Aesthetics Limited is a standalone company, no data of yours is shared with any other company except with the express purposes of the safe and legal execution of our business.
2. We may disclose your personal data to our insurers or legal advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, and obtaining professional advice.
3. Your personal data held in our website database and the Customer Relationship Management (CRM) system will be stored on the servers of our hosting services providers and CRM providers (Little Fire Digital Ltd – https://little-fire.com and Pabau https://pabau.com respectively).
4. If expressly permitted by you, we will share your contact data with our mailing list management provider Mailchimp. The data shared will be your name and your email address. You can find information about the Mailchimp’s privacy policies and practices at https://mailchimp.com/legal/.
5. Financial transactions relating to our website and services are handled by our payment services provider, Stripe https://www.stripe.com. 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/en-gb/privacy.
6. In addition to the specific disclosures of personal data set out above 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.
International transfers of your personal data
1. In Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
2. We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
3. We are a company based solely in the UK. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which can be obtained from the Information Commissioners Office https://ico.org.uk/.
4. The hosting facilities for our website are situated in the United Kingdom. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of the United Kingdom.
5. LIttle Fire Digital Limited is situated in the United Kingdom: the competent data protection authorities have made an adequacy determination with respect to the relevant data protection laws. Pabau Limited is situated in the United Kingdom: the competent data protection authorities have made an adequacy determination with respect to the relevant data protection laws. Mailchimp is situated in the United States of America: the competent data protection authorities have made an adequacy determination with respect to the relevant data protection laws of that country. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Retaining and deleting personal data
1. Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
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.
3. We will retain your personal data as follows:
  1. contact data raised from verbal and telephone enquiries will be retained from the date of first contact with us for: either the duration of your enquiry; the duration of your relationship with us as a customer or any other ongoing relationship with us – subject tos stipulations below. We reserve the right to retain written data freely submitted to us by you (for example by using an online enquiry form or an email) for no longer than seven years from the date of the last communication between both parties.
  2. account data will be retained for a minimum period of seven years following the date of closure of the relevant account, and for a maximum period of to longer than six months thereafter;
  3. customer relationship data will be retained for a minimum period of seven years following the date of termination of the relevant customer relationship and for a maximum period of six months thereafter;
  4. transaction data will be retained for a minimum period of seven years following the date of the transaction, and for a maximum period of six months thereafter;
  5. communication data will be retained for a minimum period of seven years following the date of the communication in question, and for a maximum period of six months thereafter;
  6. usage data will be retained for seven years; and
  7. medical data will be retained for a minimum period of seven years following your last treatment with us, and for a maximum period of six months thereafter.
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. Notwithstanding the above, we reserve the right to retain personal data where:
  1. Such data is required as part of our legitimate interests, namely the protection of our website, services and business, and the protection of others and for a maximum of six months thereafter.
  2. Such data pertains to any complaints or legal procedure pertaining to either ourselves or you as a client and for a maximum of six months the termination of any such procedure.
  3. Laws or regulations exist which require the retention of said data for a maximum of six months after the period of any such stipulation.
5. Notwithstanding the other provisions of this Section 7, 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.
Security of personal data
1. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
2. We will store your personal data on secure servers, secured personal computers and mobile devices and in secure manual record-keeping systems.
3. We encrypt all passwords stored to access your data either by yourself or our staff.
4. All data that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology during transit.
5. Notwithstanding the above. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the Internet is inherently insecure, and we cannot guarantee the security of data sent over the Internet. For example, we cannot vouch for the security of your email content as it is sent to us.
6. You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password except when you log in to our website. We cannot accept responsibility for data released as a result of your password being shared with others or as a result of your choice of an insecure password.
Your rights
1. In Section 9, 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.
2. Your principal rights under data protection law are:
  1. the right to access – you can ask for copies of your personal data;
  2. the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
  3. the right to erasure – you can ask us to erase your personal data;
  4. the right to restrict processing – you can ask us to restrict the processing of your personal data;
  5. the right to object to processing – you can object to the processing of your personal data;
  6. the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
  7. the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
  8. the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
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. You can access your personal data by visiting https://casafia.com/profile when logged into our website.
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.
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.
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. 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 data 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.
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.
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 interest.
10. To the extent that the legal basis for our processing of your personal data is:
  1. consent; or
  2. 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
11. Where the above 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.
12. If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. In relation to complaints under EU data protection law, you may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement; in relation to complaints under UK data protection law, you should do so in the UK.
13. To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
14. You may exercise any of your rights in relation to your personal data by written notice to us at our postal address, by email to our data protection officer (see below).
Third-party websites
1. Our website includes hyperlinks to, and details of, third-party websites.
2. In general, we have no control over, and are not responsible for, the privacy policies and practices of third parties.
Personal data of children
1. Our website and services are targeted and specifically only available to persons over the age of 18.
2. If we have reason to believe that we hold the personal data of a person under that age in our databases, we will delete that personal data.
Updating information
1. Much of the personal information we hold about you is available for you to edit online at https://casafia.com/profile. Where it is not or where you are unable to do so please contact our data protection officer if the personal information that we hold about you needs to be corrected or updated.
About cookies
1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
2. 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, on the other hand, will expire at the end of the user session, when the web browser is closed.
3. Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
1. We use cookies for the following purposes:
  1. authentication and status – on visiting the site, we set a single cookie CASAFIA_ID. This is a session cookie – and lasts for the duration of your visit to the site, This cookie contains a unique identifier which relates to data securely held on our web servers and allows us to establish whether or not you are logged in, personal relationship relating you whilst you are logged in and the contents of any shopping basket;
  2. persistent preferences – where you interact with the website in such a manner as your actions need to be ‘remembered’ – no personal information is stored in these cookies. The following cookies may be set:
    1. cookieconsent_status – required to prevent the repeated display of the cookie consent warning
    2. login return – required to return you to the page you requested after logging in
Cookies used by our service providers
1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
2. We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy.
3. We use a Facebook pixel on our website. Using the pixel, Facebook collects information about the users and use of our website. The information is used to personalise Facebook advertisements and to analyse the use of our website. To find out more about the Facebook pixel and about Facebook’s use of personal data generally, see the Facebook cookie policy at https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at https://www.facebook.com/about/privacy. The Facebook cookie policy includes information about controlling Facebook’s use of cookies to show you advertisements. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at https://www.facebook.com/help/568137493302217.
Managing cookies
1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
  1. https://support.google.com/chrome/answer/95647 (Chrome);
  2. https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
  3. https://help.opera.com/en/latest/security-and-privacy/ (Opera);
  4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
  5. https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
  6. https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).
2. Cookies are essential for the effective functioning of the site. You will be presented with the option to refuse cookies when you arrive at our website. If you do so, we cannot guarantee any part of the website will function as intended
Amendments
1. We may update this policy from time to time by publishing a new version on our website.
2. You should check this page occasionally to ensure you are happy with any changes to this policy.
3. We will notify our customers of significant changes to this policy by email.
Our details
1. This website is owned and operated by Casafia Medical Aesthetics Limited.
2. We are registered in England and Wales under registration number 13285608, and our registered office address is:
  BHP, 2 Rutland Park, Sheffield, United Kingdom, S10 2PD.
3. Our principal place of business is:
  342 Goring Road, Goring-By-Sea, West Sussex, BN12 4PD
4. You can contact us:
  1. by post, to Casafia, 342 Goring Road, Goring-By-Sea, West Sussex, BN12 4PD;
  2. using our website contact form at: https://casafia.com/contact;
  3. by telephone, using the contact number published on our website; or
  4. by email, using the email address published on our website.
Data protection registration
1. We are registered as a data controller with the UK Information Commissioner’s Office.
2. Our data protection registration number is number.
Representatives
1. Our representative with respect to our obligations under data protection law is our Data Protection Officer – contact details below.
Data protection officer
1. Our Data Protection Officer is Catherine Johnstone – catherine@casafia.com

Monday	9am–6pm
Friday	9am–6pm
Saturday	9am–6pm

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