Privacy Policy

PRIVACY POLICY

Welcome to the Beauty Academy privacy policy notice.

We are strongly committed to protecting the privacy of our website users and customers, including students who as part of their course enrolment are provided access to The Beauty Academy Student Portal. This policy relates to the personal information that you may be asked to provide when contacting us, using our website and/or The Beauty Academy Student Portal site. This includes personal data, email address and other pieces of personal data specific to you.

We set out below our guidelines to inform you of the specific information we collect, how we use this information and what options you have in sharing this information with us when you contact us, visit our website and/or student portal site.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how we collect and processes your personal data through your use of this website and/or The Beauty Academy Student Portal including any data you may provide through this website when you purchase products, register with us for courses or otherwise, or sign up to our newsletter.

This website is not intended for children and we do not knowingly collect data relating to children.

CONTACT INFORMATION

www.thebeautyacademy.org (Website) is a site owned and operated by The Beauty Academy Limited, a company registered in England and Wales, company number 04176214. Our registered office is at William James House, Cowley Road, Cambridge, CB4 0WX.

You can contact us by writing to us at the above address, emailing us at [email protected] or by calling us on 0333 800 7700 (existing students) or 0800 999 2277 for all other enquiries. Our lines are open between 9.00 am to 5.30pm Monday to Friday (excluding Bank and Public holidays).

Our privacy manager is: Terry Hadley

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CONTROLLER

The Beauty Academy Limited is the controller and responsible for your personal data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out above.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We may update this policy from time to time by updating this page, this allows our users to always be aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information in accordance with the privacy policy under which the information was collected. This policy was last updated on 9^th May 2018.

It is important that the personal data we hold about you is accurate and current. Please let us know if there are any changes to your situation, contact or personal details. This is so that we can communicate with you safely and quickly.

Please let us know straight away if any of these change:

• Your name
• Address (including if you move abroad)
• Phone number (including mobile)
• Email address

We will contact you using the most recent address, email or phone number you’ve given us. If you don’t tell us promptly about a change in your details, you may not receive information that could be important

THIRD-PARTY LINKS

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

KLARNA

In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.

General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, home and/or contact address, email address and telephone numbers.
• Financial Data. Credit card transactions are processed using our own internet merchant account and authorised via a third-party payment gateway system. The payment gateway is an authority in trusted modular payment solutions and security systems on the internet.
• Transaction Data includes details about payments to and from you and other details of your purchases with us, courses you request and any other products or services we provide.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes information relating to any courses or education you have previously attained or completed, your hobbies, interests, preferences, feedback and survey responses. Any medical information that may lead to contra-indications during training.
• Usage Data includes information about how you use our website and your purchases from us.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel an order you have with us, but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• order products from us;
• request details of products or courses from us;
• register for our educational courses;
• create an account on our website or on The Beauty Academy Portal;
• request marketing to be sent to you;
• enter a promotion or survey; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

HOW WE USE YOUR PERSONAL DATA

We are the sole owner of the information collected on our website and through our communications with you. We will not sell, distribute or lease this information to third parties unless we have your permission or are required to do so by law.

We collect information from our users at several different points on our website and the information being gathered is specified upon each form. We also may gather or verify information with you when communicating with you by telephone, email, using the Live Chat option on our website or when accessing our Student Portal website.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

(If you are reading this on a mobile device, please scroll right to see the full table)

You may choose to restrict the collection or use of your personal data by contacting us at [email protected] – please note this may mean we are unable to deliver some or all of our services to you, for which no reimbursement can be made where a course fee has already been paid.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details by at some other time and, in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any company outside of our group of companies for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by Contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Where you book a course, we will process your enrolment and you will be asked if you wish to be added to our email mailing list, which we hope you will agree to as this will ensure we are able to deliver the best level of service and communication to you. Mailing list-based marketing communications will be relevant and not excessive.

Where you do agree to be part of our mailing list, you have the option to unsubscribe at any time as an ‘unsubscribe’ option will appear at the bottom of every email newsletter sent which once clicked will immediately remove you from the mailing list and from receiving any further marketing email communications. You will still receive notifications by email in relation to any current course enrolment to include booking confirmations and updates related directly to that course. To change your communication preferences, simply contact us at any time.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURE OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

• Third Parties as defined in the Glossary;
• Shipping Companies and Suppliers;
• Examination boards and our insurance partners:
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We will not disclose your personal data to any other third parties without your specific consent unless we are required to do so by law.

INTERNATIONAL TRANSFERS

We may transfer data outside of UK/EU when our CRM utilises ‘Sendgrid’ to facilitate emails.

DATA SECURITY

We take every precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected both online and offline. When our registration/order form asks users to enter sensitive information (such as credit card number and/or contact information), that information is encrypted and is protected with 128-bit encryption over an SSL connection. While on a secure page, such as our shopping cart checkout forms, the lock icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer is displayed as locked. Furthermore, when accessing content and/or uploading documents to the Student Portal website, you are protected through an SSL (HTTPS) connection.

Any details you give will remain completely confidential. All data gathered will be processed using our secure customer relations management cloud-based software system which is supplied by the third-party provider. We are committed to ensuring that your information is secure and in order to prevent unauthorised access or disclosure, we use only an online software system that has security management processes in place which are compliant with the requirements of ISO 27001.

An email will be sent to you to provide access to the Student Portal website initially (if relevant to your course booking), at which time you will be able to set your own login password and confirm the contact details held about you. Having gained access to the Student Portal website, we would strongly recommend that you do not divulge your username and password to anyone. Please ensure that others cannot access any of your personal data especially when using a shared or public access computer terminal or open connection to the internet.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data – please see below.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data 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 data 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.
• Object to processing of your personal data 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 data 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.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data 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 data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that 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.
• Withdraw consent at any time where we are relying on consent to process your personal data. 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.

You will not have to pay a fee to access your personal data (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 may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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.

GLOSSARY

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties:

• Service providers acting as processors based who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide banking, legal, insurance and accounting services.
• HM Revenue & Customs (and like bodies outside of the UK), regulators and other authorities who require reporting of processing activities in certain circumstances.

Shipping Companies and Suppliers means those third-party shipping companies e.g. Royal Mail, UPS etc we use to ship orders of physical products such as starter kits, and third party suppliers of products such as starter kits which supply products direct to our customers. Information may be provided to these companies only with the express purpose of being able to directly supply your ordered product/service to you. These companies do not retain, share, store or use personally identifiable information for any secondary purposes.

COOKIE POLICY

We respect the privacy of all our visitors to the website, and Student Portal website (access to which is only provided to registered students). The Cookie Policy outlines our policy concerning the use of cookies, web beacons and similar technologies. Cookies, web beacons and similar technologies are small text files stored on your computer, mobile, tablet or other device used on the Internet, which helps to collect information from your device.

HOW WE USE COOKIES

We use information gathered from cookies to help improve your experience of our website(s). Some cookies are essential, so you can navigate the website and use its features. We use Google Analytics to collect traffic data about how users use our website(s) and what content is most useful to our visitors. Targeting and advertising related to cookies are used to deliver advertising that is most relevant to you and your interests. They are also used to limit the number of times you see an advert as well as to measure the effectiveness of the advertising campaign. Where and if used, they are usually placed by the advertising networks with our permission.

COOKIES IN RELATION TO YOUR SHOPPING CART

We will store a persistent cookie so that you may retrieve the products in your shopping cart with no need to go through re-choosing all of them again. However, the cookies will eventually expire if there is no activity in your cart e.g. view, add to etc. for a number of days. This website’s cookies do not contain any personally identifiable information.

THIRD PARTY COOKIES

Some cookies are not related to us. They have been set on our website by others, for example when you visit a page embedded with content such as YouTube or Facebook, these service providers may set their own cookies on your web browser. We do not control the use of these cookies and cannot access them due to the way that cookies work, as cookies can only be accessed by the party that originally set them. You should check third party websites for more information about these cookies.

MARKETING COMMUNICATIONS

If you have signed up to receive marketing communications, we may combine information collected through these cookies, web beacons, your device identifier etc. with your profile of information provided directly by you. This is so we can provide you with more tailored content.

YOUR CHOICES REGARDING COOKIES

If you do not want any information collected via a site cookie on our website or Student Portal website, you can use your browser settings to deny or accept any individual or all cookies. Each browser is different so check your browser’s Help menu to learn how to modify your cookies. If you turn off cookies, you may not have access to some features or functionality on all or part of our websites that otherwise improve your experience. Services such as access to the Student Portal which require login may not work without allowing cookies.

It is important to ensure you are happy to accept cookies if wishing to complete a course requiring use of the Student Portal, before booking as no cancellations or refunds can be provided on such basis where you are unable to access the course materials or to participate. More information about cookies and details of how to manage or disable them can be found at www.aboutcookies.org

DISCLAIMER

The information contained in this website and upon the Student Portal website is for general information purposes only. While we endeavour to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the websites or the information, products, services or related graphics contained on the websites for any purpose. Any reliance you place on such information is therefore at your own risk.

In no event will we be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of, or in connection with the use of this website or the Student Portal website.

Through this website and the Student Portal website, you are able to link to other websites which are not under our control. We have no control over the nature, content and availability of those sites. The inclusion of any links does not necessarily imply a recommendation or endorse the views expressed within them.

YOUR FEEDBACK

If you have any questions about our privacy statement, the practices of our sites, or your dealings with us, please contact us and let us know. Alternatively, if you have any specific questions, please email us at [email protected]