PRIVACY POLICY

1. What type of information do you collect?

We may collect and use the following personal information about you:

•        Identity Data which includes your first name and last name, title, date of birth and gender and information that enables us to check and verify your identity, such as your identity card number.

•        Contact Data which includes your billing address, delivery address, email address and telephone number.

•        Financial Data which includes billing and payment card details.

•        Transaction Data which includes details about payments and products and services you have purchased from us.

•        Treatment Data which includes details regarding the treatments provided to you at our medical spa and, if relevant to the treatment requested by you, details about your health.

•        Feedback Data which includes information relating to feedback provided to us and your responses to surveys.

•        Usage Data which includes information relating to your use of our website.

•        Marketing and Communications Data which includes your preferences in receiving marketing material from us and our third-party partners.

Where we need to collect personal information by law, or in order to be able to provide our products or services to you and you fail to provide that information when requested, this may prevent or delay us from providing our products or services to you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. We do not usually collect and use personal information of children (i.e. individuals who are under the age of sixteen). Where needed to collect and use such personal information, we do so only provided that we have first obtained their parents’ or legal guardian’s consent or we are otherwise permitted or required under the law.

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2. How do you collect information?

We collect most of this personal information directly from you—in person, by telephone, or email, via any forms we may ask you to fill in and via our website.

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3. Why do you collect such personal information?

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

•        to comply with our legal and regulatory obligations;

•        for the performance of our agreement with you or to take steps at your request before entering into an agreement;

•        for our legitimate interests or those of a third party, where your interests and fundamental rights do not override our interests or those of a third party;

•        where you have given your consent; or

•        for the provision of treatment

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

•        Operational reasons, such as improving efficiency, training and quality control

•        Preventing and detecting fraud

•        Preventing un-authorised access and modifications to systems

•        Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures

•        Ensuring safe working practices, staff administration and assessments

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4. What do you use your visitors' personal information for?

The table below explains what we use (process) your personal information for and the legal bases which we rely on to do so:

What we use your personal information for

To provide our products, services and treatments to you including:

(a) to process and deliver your order or request

(b) allocate the correct therapist to provide the treatment to you

(c) manage payments, fees and charges

(d) collect and recover money owed to us
- Identity Data

- Contact Data

- Financial Data

- Transaction Data

- Treatment Data

(e) Performance of a contract with you or to taking steps at your request before entering into a contract

(f) Necessary for our legitimate interests (record and administer our transactions)

(g) Necessary to comply with our legal and regulatory obligations

(h) Your explicit consent, as far as special categories of data are concerned

(i) For the provision of treatment

To manage our relationship with you will include:

(a) to register you as a new customer

(b) Notifying you about changes to how we operate our business or the way we deal with you

(c) Updating the information we have about you

(d) Asking you to leave a review or take a survey

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5.     Promotional and Marketing communications
We may use your personal information to send you updates (by email, text message, telephone, app notifications or post) about our products and services, including exclusive offers, promotions or new products and services.

We rely on your consent to send you promotional and marketing communications and we will ask for this consent separately and clearly.

Where you have provided your consent for promotional and marketing communications, you have the right to withdraw it at any time by:

•        emailing, calling or writing to us—see below: ‘Contact Information’

•        using the ‘unsubscribe’ link in emails or ‘STOP’ number in text messages

We will always treat your personal information with the utmost respect and never share it for marketing purposes with other organisations outside our group.

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6. Your rights
You have the following rights in relation to your personal information:

Access
The right to be provided with a copy of your personal information.
Rectification
The right to require us to correct any mistakes in your personal information. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
To be forgotten
The right to require us to delete your personal information (in certain circumstances). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Restriction of processing
The right to require us to restrict processing of your personal information (in certain circumstances). This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
Data portability
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
To object
The right to object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Not to be subject to automated individual decision-making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
Withdraw consent
The right to withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
For further information on each of those rights, including the circumstances in which they apply, please contact us or visit the website of the Commissioner for the Protection of Personal Data (www.dataprotection.gov.cy).

If you would like to exercise any of those rights, please:

•        email, call or write to us—see below: ‘How to contact us’;

•        let us have enough information to identify you;

•        let us have proof of your identity; and

•        let us know what right you want to exercise and the information to which your request relates.

You will not have to pay a fee to access your personal information or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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7. How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.

The GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Cyprus is the Commissioner for Personal Data Protection who can be contacted at 1 Iasonos street, 2nd floor, 1082 Nicosia; tel: 22818456; fax: 22304565; email: commissioner@dataprotection.gov.cy; www.dataprotection.gov.cy.  

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8. Privacy policy updates

We may change this privacy policy from time to time. When we do we will post the updated privacy policy on our website and we will also inform you via email if you are on our mailing list.

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9. Contact Information

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Aphrodite 5,

7041 Oroklini,

Larnaca, Cyprus

Email: info@auraspa-cy.com

Tel: 357-24-333444

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